April 22, 2019

Donald Allan, Jr.
Executive Vice President and Chief Financial Officer
Stanley Black & Decker, Inc.
1000 Stanley Drive
New Britain, CT 06053

       Re: Stanley Black & Decker, Inc.
           Form 10-K for Fiscal Year Ended December 29, 2018
           Filed February 26, 2019
           Form 8-K Filed January 22, 2019
           File No. 001-05224

Dear Mr. Allan:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for Fiscal Year Ended December 29, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Estimates
Goodwill and Intangible Assets, page 39

1.    We note, for your annual goodwill impairment test, you performed the
quantitative test for
      three of your reporting units. Please expand your disclosure to identify
those reporting
      units and indicate, if true, that the fair values of those reporting
units are substantially in
      excess of their carrying values. Identify for us any reporting units with
a fair value not
      substantially in excess of their carrying value and quantify the related
goodwill associated
      with those reporting units. For any reporting unit with a fair value not
substantially in
      excess of their carrying value, please provide investors with additional
information
      regarding the risk associated with the reporting unit, including the
following information
      necessary to assess the probability of a future material impairment
charge:
 Donald Allan, Jr.
Stanley Black & Decker, Inc.
April 22, 2019
Page 2


             The percentage by which fair value exceeded carrying value as of
the date of the most
             recent test;
             The amount of goodwill allocated to the reporting unit;
             A description of the key assumptions used and how the key
assumptions were
             determined;
             A discussion of the degree of uncertainty associated with the key
assumptions. The
             discussion regarding uncertainty should provide specifics to the
extent possible; and
             A description of potential events and/or changes in circumstances
that could
             reasonably be expected to negatively affect the key assumptions.

         Refer to Item 303(a)(3)(ii) of Regulation S-K and Section V of
Interpretive Release No.
         33-8350.
Form 8-K Filed January 22, 2019, page 4

2.       We note you present Non-GAAP Adjusted EPS guidance for fiscal year
2019 in your
         earnings release without reconciling to the corresponding GAAP
amounts. Please review
         the guidance provided in Question 102.10 of the Non-GAAP Financial
Measures
         Compliance and Disclosure Interpretations when preparing your next
earnings release.
        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.

       You may contact Tracie Mariner, Staff Accountant, at (202) 551-3744, or
Melissa Rocha,
Senior Assistant Chief Accountant, at (202) 551-3854, if you have questions
regarding
comments on the financial statements and related matters.



                                                              Sincerely,
FirstName LastNameDonald Allan, Jr.
                                                              Division of
Corporation Finance
Comapany NameStanley Black & Decker, Inc.
                                                              Office of
Manufacturing and
April 22, 2019 Page 2                                         Construction
FirstName LastName