1.

We note your response to comment 1 in our letter dated May 12, 2015. Specifically, we note your statements in the footnote to page 2 that you did receive “a directional reference (i.e., “above X amount”).” We further note your discussion that the overture you received was not “a precise or defined number” and was not “in a range that the Company was willing to consider in any settlement discussions.” It is not clear to us whether your threshold for disclosing the amount or range of reasonably possible loss in excess of accrual is consistent with the requirements in ASC 450-20-50-3 through 50-5, as precision or certainty is not required when disclosing the amount or range of reasonably possible loss in excess of accrual. Given that management had assessed the amount or range for a settlement related to the various foam antitrust lawsuits, it is unclear why an amount or range of reasonably possible loss in excess of accrual was not disclosed for the foam antitrust lawsuits prior to the tentative settlements reached between August 2014 and the beginning of fiscal year 2015. Please confirm you will make an effort to develop estimates for purposes of disclosure for all of your material loss contingencies, consistent with the requirements of ASC 450-20-50, including determining which of the potential outcomes are reasonably possible and what the reasonably possible range of losses would be for those reasonably possible outcomes. Please note that the disclosure requirement in ASC 450-20-50-3 through 50-5 may be provided on an aggregate basis.

(i)	Leggett is responsible for the adequacy and accuracy of the disclosure in the filing;

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(ii)	Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

(iii)	Leggett may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.