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                              May 15, 2020

       Robert Roche
       Vice President and Chief Financial Officer
       CARLISLE COMPANIES INC
       16430 North Scottsdale Road
       Suite 400
       Scottsdale, Arizona 85254

                                                        Re: CARLISLE COMPANIES
INC
                                                            Form 10-K for
Fiscal Year Ended December 31, 2019
                                                            Form 10-Q for
Fiscal Quarter Ended March 31, 2020
                                                            File No. 1-09278

       Dear Mr. Roche:

             We have reviewed your filings and have the following comment. In
our comment, we
       may ask you to provide us with information so we may better understand
your disclosure.

              Please respond to our comment 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
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to our comment, we may have additional comments.

       Form 10-Q for the period ended March 31, 2020

       Notes to Condensed Consolidated Financial Statements (Unaudited)
       Goodwill and Other Intangible Assets, net, page 15

   1.                                                   We note your disclosure
that, due to general market declines driven by the coronavirus
                                                        global pandemic, you
performed impairment testing on your goodwill and indefinite-lived
                                                        intangible assets. In
both cases, you determined that the fair values of these assets
                                                        exceeded their carrying
value.

                                                        In order to provide
investors with information to better assess the probability of future
                                                        goodwill impairment
charges, please disclose, if accurate, that the estimated fair values of
                                                        the intangible assets
you quantitatively tested for impairment substantially exceeded their
                                                        carrying values. For
any asset whose estimated fair value did not substantially exceed its
                                                        carrying value, please
disclose the percentage by which fair value exceeded carrying value
                                                        at the date of the most
recent test.
 Robert Roche
CARLISLE COMPANIES INC
May 15, 2020
Page 2

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or
John Cash,
Accounting Branch Chief, at (202) 551-3768 if you have questions regarding
comments or
related matters.



FirstName LastNameRobert Roche                            Sincerely,
Comapany NameCARLISLE COMPANIES INC
                                                          Division of
Corporation Finance
May 15, 2020 Page 2                                       Office of
Manufacturing
FirstName LastName