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United States securities and exchange commission logo
September 28, 2022
Jeffrey L. Tate
Executive Vice President and Chief Financial Officer
Leggett & Platt, Incorporated
No. 1 Leggett Road
Carthage, Missouri 64836
Re: Leggett & Platt,
Incorporated
Form 10-K for
Fiscal Year Ended December 31, 2021
Response Dated
September 7, 2022
File No. 001-07845
Dear Mr. Tate:
We have reviewed your September 7, 2022 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
August 25, 2022 letter.
Response Dated September 07, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
31
1. We note from your
response to prior comment six that you did not experience any
material physical
effects or damage to your operations due to severe weather. As your
response notes that the
weather-related events you have experienced include flash floods,
windstorms, tornadoes
and a hailstorm, please explain how you considered providing
disclosure regarding
the potential for the significant physical effects of climate change to
affect your operations
and results.
Jeffrey L. Tate
FirstName LastNameJeffrey
Leggett & Platt, IncorporatedL. Tate
Comapany 28,
September NameLeggett
2022 & Platt, Incorporated
September
Page 2 28, 2022 Page 2
FirstName LastName
Please contact Erin Donahue at 202-551-6063 or Ethan Horowitz at
202-551-3311 with
any questions.
Sincerely,
Division of Corporation
Finance
Office of Manufacturing