August 18, 2011
VIA EDGAR AND OVERNIGHT MAIL
United States Securities and Exchange Commission |
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Division of Corporation Finance |
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100 F Street N.E. |
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Washington, D.C.20549 |
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Attention: | Mr. Shehzad Niazi | |
| Mr. David Link | |
Re: | The Timberland Company |
| Schedule 14C |
| Filed July 18, 2011 |
| File No. 001-09548 |
Dear Mr. Niazi and Mr. Link:
In connection with the response of The Timberland Company (the “Company”) to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in its letter dated August 12, 2011, the Company acknowledges that:
· it is responsible for the adequacy and accuracy of the disclosure in the filing;
· Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and
· it 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.
If you have any questions, please do not hesitate to call Jane D. Goldstein at (617) 951-7431 or Zachary R. Blume at (617) 951-7663 at Ropes & Gray LLP.
| THE TIMBERLAND COMPANY | |
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| /s/ Danette Wineberg | |
| Name: | Danette Wineberg |
| Title: | Vice President, General Counsel and Secretary |