| 1. | We note your response to comment 3 in our letter dated March 26, 2009. However, disclosure regarding the releif sought is required under Item 103 of Regulation S-K. We would not object if you include language similar to the last paragraph of your response to this comment in your future disclosure. Therefore, please provide this information in future filings. |
We will include disclosure similar to the following in future filings beginning with our Form 10-Q for the six months ended June 30, 2009. Of the 50,000 claims outstanding at the end of 2008, approximately 96% were filed by plaintiffs who do not claim a specific amount of damages or claim a minimum amount as established by court rules relating to jurisdiction; approximately 2% were filed by plaintiffs who claim damages of less than $5 million; approximately 2% were filed by plaintiffs who claim damages from $5 million to less than $100 million (90% of whom claim damages from $10 million to less than $25 million) and one was filed by a plaintiff who claims damages of $111 million. |
| • | Crown is responsible for the adequacy and accuracy of the disclosure in Crown’s filings; | |
| • | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and | |
| • | Crown 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. |
| Crown Holdings, Inc. | |
/s/ Thomas A. Kelly Thomas A. Kelly Senior Vice President and Corporate Controller |
