December 21, 2007



Via EDGAR

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-7010
Attention:  John Cash, Accounting Branch Chief

Re:   Watts Water Technologies, Inc.
      Form 10-K for the Fiscal Year Ended December 31, 2006
      Form 10-Q for the Fiscal Quarter Ended April 1, 2007
      Form 10-Q for the Fiscal Quarter Ended July 1, 2007
      Form 10-Q for the Fiscal Quarter Ended September 30, 2007
      File No. 001-11499

Dear Mr. Cash:

On behalf of Watts Water Technologies, Inc. (the "Company"), I have set forth
below responses to the comments to the Company's Annual Report on Form 10-K for
the Fiscal Year Ended December 31, 2006 and Quarterly Reports on Form 10-Q for
the Fiscal Quarters Ended April 1, 2007, July 1, 2007, and September 30, 2007,
provided to me in your letter dated December 19, 2007 (the "Letter"). The
responses are keyed to the numbering of the comments in the Letter and to the
headings used in the Letter.

Form 10-K for the Fiscal Year Ended December 31, 2006

Consolidated Statements of Cash Flows, page 61

1.    We note that in your presentation of operating activities under the
      indirect method, you begin with a reconciliation of "income from
      continuing operations." In future filings, please revise your statements
      of cash flows to begin your reconciliation with "net income" as required
      by paragraph 28 of SFAS 95.

Response

      The Company respectfully acknowledges the Staff's comment and will revise
      its disclosure in future filings.



Securities and Exchange Commission
Attn:  John Cash, Accounting Branch Chief
December 21, 2007
Page 2


Note 17 - Segment Information, page 94

2.    In future filings, please revise your disclosure to include a
      reconciliation of your total of your segments' measure of profit or loss,
      which appears to be operating income (loss), to your consolidated income
      from continuing operations before income taxes as required by paragraph
      32(b) of SFAS 131.

Response

      The Company respectfully acknowledges the Staff's comment and will revise
      its disclosure in future filings.

Form 10-Q for the Fiscal Quarter Ended September 30, 2007

Note 5 - Restructuring and Other Charges, page 12

3.    We note your initiation of a global restructuring program and the
      continued discontinuance of certain product lines during the third quarter
      of 2007. In this regard, we remind you follow the disclosure requirements
      as provided by paragraph 20 of SFAS 146 and provide the reconciliation of
      the liability balance as provided in paragraph 20b(2) of SFAS 146.

Response

      The Company respectfully acknowledges the Staff's comment and will include
      such disclosure in future filings.

The Company hereby acknowledges that:

      (i)   it is responsible for the adequacy and accuracy of the disclosure in
            its filings;

      (ii)  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

      (iii) the Company may not assert the Staff comments as a defense in any
            proceeding initiated by the Commission or any person under the
            federal securities laws of the United States.


Securities and Exchange Commission
Attn:  John Cash, Accounting Branch Chief
December 21, 2007
Page 3


Please telephone the undersigned at (978) 689-6207 with any questions or
comments concerning this filing.


Very truly yours,


/s/ William C. McCartney
- ------------------------
William C. McCartney
Chief Financial Officer

Cc:   Dale Welcome