-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, I+5ovhoyk7/pEpoL0hrAwmmhtbHS66of8zqV+isMh0OGzKpJ+6UiFHF2lwu1baqT 3qV9xpFt/T2W3jDx4S5n6Q== 0000089439-08-000005.txt : 20080414 0000089439-08-000005.hdr.sgml : 20080414 20080206115850 ACCESSION NUMBER: 0000089439-08-000005 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20080206 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MUELLER INDUSTRIES INC CENTRAL INDEX KEY: 0000089439 STANDARD INDUSTRIAL CLASSIFICATION: ROLLING DRAWING & EXTRUDING OF NONFERROUS METALS [3350] IRS NUMBER: 250790410 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: SUITE 150 STREET 2: 8285 TOURNAMENT DRIVE CITY: MEMPHIS STATE: TN ZIP: 38125 BUSINESS PHONE: (901)753-3200 MAIL ADDRESS: STREET 1: SUITE 150 STREET 2: 8285 TOURNAMENT DRIVE CITY: MEMPHIS STATE: TN ZIP: 38125 FORMER COMPANY: FORMER CONFORMED NAME: SHARON STEEL CORP DATE OF NAME CHANGE: 19910103 CORRESP 1 filename1.txt Mueller Industries, Inc. 8285 Tournament Drive, Suite 150 Memphis, TN 38125 February 6, 2008 Via EDGAR Mr. John Cash Accounting Branch Chief United States Securities and Exchange Commission Washington, D.C. 20549-7010 RE: Mueller Industries, Inc. Form 10-K for the Fiscal Year Ended December 30, 2006 Definitive Proxy Statement on Schedule 14A Filed March 27, 2007 Form 10-Q for the Fiscal Quarter Ended March 31, 2007 Form 10-Q for the Fiscal Quarter Ended June 30, 2007 Form 10-Q for the Fiscal Quarter Ended September 29, 2007 File No. 001-06770 Dear Mr. Cash: We have reviewed your letter dated January 25, 2008. Following are the staff's comments followed by our responses, which are numbered to correspond with the numbers set forth in the staff's comment letter: Definitive Proxy Statement on Schedule 14A Filed March 27, 2007 Compensation Discussion and Analysis, page 19 1. We note your response to prior comment 7. In future filings, please disclose that the decisions regarding the awards of the various elements of compensation are generally independent of one another and that a decision regarding one element of compensation does not affect decisions regarding other compensation elements. Company response: Your comment is noted and we will include the appropriate disclosure commencing with the Company's 2008 Proxy Statement. Report of the Compensation Committee on the Board of Directors on Executive Compensation, page 43 2. We note your intended 2008 Proxy Statement disclosure included in your response to prior question 8. Please note that you must also include the names of the compensation committee members below the disclosure. See Item 407(e)(5)(ii) of Regulation S-K. -1- Company response: Your comment is noted and we will include the names of the compensation committee members below the disclosure as was done on page 43 of our March 27, 2007 filing. If you have further questions or require additional information, you may contact me by telephone at (901)753-3208 or you may contact Richard Corman, Vice President-Controller, at (901)753-3217. Sincerely, /s/Kent A. McKee Kent A. McKee Executive Vice President and Chief Financial Officer -2- -----END PRIVACY-ENHANCED MESSAGE-----