Hubbell Incorporated

584 Derby Milford Road
Orange, CT 06477
203 799-4100
203-799-4333 Fax

May 14, 2010

VIA EDGAR

Celeste M. Murphy, Legal Branch Chief
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

Re: Hubbell Incorporated
Form 10-K for the fiscal year ended December 31, 2009
Filed: February 19, 2010
File No. 1-2958

Dear Ms. Murphy:

The purpose of this letter is to acknowledge the receipt by Hubbell Incorporated (the “Company”) of the comment of the staff of the Securities and Exchange Commission in your letter dated May 11, 2010 to Mr. Timothy H. Powers with respect to the Company’s Form 10-K for the fiscal year ended December 31, 2009. For ease of reference, your comment is repeated in italics below and followed by the Company’s response.

Board Oversight of Risk, page 12 of the Definitive Proxy Statement

1. We note your disclosure related to the board’s leadership structure and risk oversight in response to Item 407(h) of Regulation S-K. In future filings, please also discuss the effect that the board’s role in the risk oversight of the company has on the board’s leadership structure.

In future filings, the Company hereby confirms its intention to revise its disclosure in accordance with the foregoing comment.

* * *

Hubbell Incorporated acknowledges that it is responsible for the adequacy and accuracy of the disclosure in its filing; staff comments or changes to disclosure in response to comments do not foreclose the Commission from taking any action with respect to the filing; and Hubbell Incorporated 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 or comments in connection with this response please call the undersigned at (203) 799-4230 or Megan C. Preneta, Assistant General Counsel and Assistant Secretary, at (203) 799-4210.

Very truly yours,
 

/s/ Richard W. Davies  

Richard W. Davies 

Vice President, General Counsel and Secretary 

cc: Timothy H. Powers, Chairman, President and Chief Executive Officer, Hubbell Incorporated

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