jjenkins@calfee.com 216.622.8507Direct |
Calfee, Halter & Griswold LLP Attorneys at Law
1400 KeyBank Center 800 Superior Avenue Cleveland, Ohio 44114-2688 216.622.8200 Phone 216.241.0816 Fax www.calfee.com |
September 3, 2008
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E. – Mail Stop 7010
Washington, D.C. 20549
| Re: | The J. M. Smucker Company |
| Preliminary Proxy Statement on Schedule 14A |
| File No. 1-05111 |
Ladies and Gentlemen:
As discussed with and requested by the staff today, in connection with the above-captioned preliminary Proxy Statement and on behalf of The J. M. Smucker Company (“Smucker”), we have provided herewith as Attachment 1 a statement from Smucker acknowledging that:
| • | Smucker 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 |
| • | Smucker 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. |
Smucker greatly appreciates the staff’s assistance in connection with this filing. If there is anything that we can do to facilitate the staff’s review of the amended proxy materials, please contact the undersigned or, in my absence, Kristofer Spreen ((216) 622-8826, kspreen@calfee.com).
Very truly yours,
/s/ John J. Jenkins
John J. Jenkins
| cc: | Richard Smucker |
| Timothy Smucker |
| Mark Belgya |
| Ann Harlan |
| E.J. Wunsch |
| Kristofer Spreen |
| Cleveland | Columbus | |||
Attachment 1
Acknowledgment
In connection with the filing of its preliminary Proxy Statement (Commission File No. 1-05111), The J. M. Smucker Company (“Smucker”) hereby acknowledges that:
| • | Smucker 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 |
| • | Smucker 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. |
| The J. M. Smucker Company | ||
| By: | /s/ Barry C. Dunaway | |
| Barry C. Dunaway | ||
Senior Vice President, Corporate and Organization Development | ||
| Dated: | September 3, 2008 |