|
| VICTOR P. PATRICK |
January 30, 2009 |
| Vice Chairman, CFO |
|
| and General Counsel |
Via Edgar
James Giugliano, Staff Accountant
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549-7010
Re: |
| Walter Industries, Inc. |
|
| Form 10-K for Fiscal Year Ended December 31, 2007 |
|
| Filed March 7, 2008 |
|
| Form 10-Q for Fiscal Quarter Ended June 30, 2008 |
|
| Filed August 8, 2008 |
|
| Response Letter dated October 31, 2008 |
|
| File No. 001-13711 |
Dear Mr. Giugliano:
This will confirm that we are in receipt of the Staff’s comment letter dated January 16, 2009, regarding the Company’s Form 10-K for the year ended December 31, 2007, the Company’s Form 10-Q for the quarter ended June 30, 2008, and the Company’s response letter dated October 31, 2008, with our response requested within 10 business days.
In order to review our response fully with our independent auditors and our Audit Committee, the Company plans to submit its formal responses to the Staff’s comments on or before February 13, 2009. We appreciate your consideration in this regard.
| Sincerely, |
|
|
| /s/ Victor P. Patrick |
VPP:jm