2000 N. M-63 • BENTON HARBOR, MI 49022-2692
Daniel F. Hopp
Senior Vice President, Corporate Affairs,
General Counsel and Secretary
Phone: 269-923-3223
Fax: 269-923-3722
February 28, 2008
VIA EDGAR AND COURIER
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Mail Stop 3720
Washington, D.C. 20549
Attention: | Kathleen Krebs |
Re: | Whirlpool Corporation |
Definitive Proxy Statement on Schedule 14A |
Filed on March 12, 2007 |
File No. 001-03932 |
Dear Ms. Krebs:
This will confirm our telephone conversation today in which you described the Commission’s position that Regulation S-K Item 402 (b)(2)(xiv) requires the naming of all companies included in any data set used to “benchmark the targeted amount of total retirement benefits” to our named executive officers. You also acknowledged that the Commission has not articulated a specific definition of the term “benchmark.”
We very much appreciate the clarity you provided on this point and this will confirm our commitment to continue to comply with the requirements of Regulation S-K Item 402 (b)(2)(xiv) in our future filings.
I trust that the foregoing is responsive to your request. All inquiries, questions, comments, notices and orders with respect to this letter should be directed to the undersigned at (269) 923-3223 or via facsimile at (269) 923-3722.
Sincerely,
/s/ Daniel F. Hopp
Daniel F. Hopp
Securities and Exchange Commission
February 28, 2008
Page 2
cc: | Paul G. Stern, Ph.D. |
Chair,Human Resources Committee of the Board of Directors of Whirlpool Corporation |
Jeff M. Fettig |
Chairman of the Board and Chief Executive Officer,Whirlpool Corporation |
Roy W. Templin |
Executive Vice President and Chief Financial Officer,Whirlpool Corporation |
David A. Binkley |
Senior Vice President, Global Human Resources,Whirlpool Corporation |
Robert J. LaForest |
Vice President and Associate General Counsel,Whirlpool Corporation |
Robert M. Hayward |
Kirkland & Ellis LLP |