September 9, 2024

Allen J. Mistysyn
Senior Vice President     Finance and Chief Financial Officer
The Sherwin-Williams Company
101 West Prospect Avenue
Cleveland, Ohio 44115-1075

       Re: The Sherwin-Williams Company
           Form 10-K for the Fiscal Year Ended December 31, 2023
           File No. 001-04851
Dear Allen J. Mistysyn:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2023
Item 7: Management's Discussion and Analysis of Financial Condition and Results
of Operations
Outlook, page 24

1.     We note there are $1.100 billion of long-term debt maturities due in
2024 that are
       expected to be refinanced at higher interest rates. Please discuss the
expected effects of
       this known trend or uncertainty on your future financial position,
results of operations,
       and cash flows. See Item 303 of Regulation S-K. Note that this comment
also applies to
       the $1.051 billion of long-term debt maturities due in 2025.
Non-GAAP Financial Measures
Free Cash Flow, page 34

2.     We note you include an adjustment in your calculation of free cash flow
that is not
       typically included in the calculation of the measure. Please revise the
title of the measure
       to "adjusted" free cash flow. Refer to Question 102.07 of the Non-GAAP
Financial
       Measures Compliance and Disclosure Interpretations.
 September 9, 2024
Page 2


Adjusted Diluted Net Income Per Share and Adjusted Segment Profit, page 35

3.     We note that you exclude acquisition-related amortization expense
relating to the Valspar
       acquisition from adjusted segment profit and adjusted diluted net income
per share.
       Please revise to more clearly describe the nature of the amortization
being excluded and
       why, and clarify that the related revenue being generated from these
assets is not also
       being excluded.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       Please contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at
202-551-3307
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services