January 21, 2015 Michael J. Solecki Jones Day
[email protected] Re: The Sherwin-Williams Company Dear Mr. Solecki: This is in regard to your letter dated January 21, 2015 concerning the shareholder proposal submitted by CHE Trinity Health, Everence Financial, on behalf of the Praxis Growth Index Fund, and Friends Fiduciary Corporation for inclusion in Sherwin- Williams’ proxy materials for its upcoming annual meeting of security holders. Your letter indicates that the proponents have withdrawn the proposal and that Sherwin- Williams therefore withdraws its December 11, 2014 request for a no-action letter from the Division. Because the matter is now moot, we will have no further comment. Copies of all of the correspondence related to this matter will be made available on our website at http://www.sec.gov/divisions/corpfin/cf-noaction/14a-8.shtml. For your reference, a brief discussion of the Division’s informal procedures regarding shareholder proposals is also available at the same website address. Sincerely, Adam F. Turk Attorney-Adviser Enclosure cc: Sanford Lewis
[email protected] JONES DAY NORTHPOINT • 901 LAKESIDEAVENUE • CLEVELAND,OHIO 44114.1190 TELEPHONE: + 1.216.586.3939 • FACSIMILE: + 1 .216.579.0212 January 21,2015 VIAE-MAIL shareholderoroposals@sec. gov U.S. Securities and Exchange Commission Division of Corporation Finance Office of Chief Counsel 100 F Street, N.E. Washington, DC 20549 Re: The Sherwin-Williams Company- Omission of Shareholder Proposal Securities Exchange Act of 1934 - Rule 14a-8 Dear