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                             November 28, 2023

       Patrick Hallinan
       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 the
Year Ended December 31, 2022
                                                            Form 8-K furnished
October 27, 2023
                                                            File No. 001-05224

       Dear Patrick Hallinan:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments.

              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 Year Ended December 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations
       Certain Items Impacting Earnings and Non-GAAP Financial Measures, page
31

   1.                                                   We note that in your
table disclosing the Non-GAAP adjustments to certain GAAP
                                                        measures on page 32 and
33, you disclose an Operating Profit measure that has a GAAP
                                                        amount associated with
it and a Non-GAAP amount after adjusting for acquisition-related
                                                        charges and other. We
also note that the audited statements of operations do not include a
                                                        subtotal for Operating
Profit, and it appears that the amount disclosed in MD&A has been
                                                        calculated from the
statement of operations as Net Sales less Cost of Sales (Gross Profit)
                                                        less SG&A and provision
for credit losses. It appears in calculating this Operating Profit
                                                        measure, referred to as
   GAAP    in your MD&A section, you have excluded at a
                                                        minimum, asset
impairment charges, restructuring charges, and intangible asset
                                                        amortization charges,
all of which are considered operating expenses under GAAP. In
                                                        light of the exclusion
of these expenses, this Operating Profit measure would be
 Patrick Hallinan
FirstName  LastNamePatrick
Stanley Black  & Decker, Inc.Hallinan
Comapany 28,
November   NameStanley
               2023      Black & Decker, Inc.
November
Page  2    28, 2023 Page 2
FirstName LastName
         considered a Non-GAAP measure, should be retitled to avoid being
confused with GAAP
         Operating Profit and needs to include all disclosures required by Item
10(e) of Regulation
         S-K. Please revise accordingly. Your disclosures in your Form 10-Q and
earnings
         releases on Form 8-K should be similarly revised. See also Question
100.05 of the SEC's
         Compliance and Disclosure Interpretation on Non-GAAP Financial
Measures.
2.       We note from your table on page 32 that you adjust certain GAAP
measures for
         acquisition related and other charges to present corresponding
non-GAAP measures. We
         further note that these adjustments to SG&A include
integration-related costs and a
         voluntary retirement program. Please provide us more detail as to the
nature and amounts
         related to these charges. Additionally, we note that you include a
similar Non-GAAP
         table in your Form 10-Q reports. You disclose that the Non-GAAP
adjustments to Gross
         profit primarily pertain to footprint actions and other costs
associated with the supply
         chain transformation, and the Non-GAAP adjustments to SG&A primarily
related to costs
         of providing transition services for previously divested businesses
and supply chain
         transformation costs. Please provide us more detail as to the nature
of the footprint
         actions and supply chain transformation costs. Specifically, please
tell us why you believe
         these costs are appropriate non-GAAP adjustments and do not represent
normal operating
         costs.
2023 Outlook, page 37

3.       We note your disclosure that the difference between 2023 diluted
earnings per share
         outlook and the diluted earnings per share range, excluding charges,
is approximately
         $1.15 to $1.65, consisting of acquisition-related charges and other
charges primarily due
         to supply chain transformation under the Global Cost Reduction
Program. We also note
         similar disclosures in your 10-Q filings. Please provide us more
information about the
         nature and amount of each of these types of adjustments. Specifically,
please tell us why
         you believe that these represent appropriate non-GAAP adjustments and
are not normal
         recurring expenses. See Question 100.01 of the SEC's Compliance and
Disclosure
         Interpretations on Non-GAAP Financial Measures.
Audited Financial Statements
Statement of Cash Flows, page 66

4.       We note that the reconciliation included within the operating
activities section of your
         statement of cash flow begins with a line for net earnings from
continuing operations,
         followed by a line for net earnings from discontinued operations.
Please revise future
         filings to begin your reconciliation with net income. Refer to
guidance in ASC 230-10-
         45-29.
 Patrick Hallinan
FirstName  LastNamePatrick
Stanley Black  & Decker, Inc.Hallinan
Comapany 28,
November   NameStanley
               2023      Black & Decker, Inc.
November
Page  3    28, 2023 Page 3
FirstName LastName
Notes to the Audited Financial Statements
Note P. Business Segments and Geographic Areas, page 105

5.       We note that the Tools & Outdoor segment is comprised of Power Tools
Group (PTG),
         Hand Tools, Accessories & Storage (HTAS), and Outdoor Power Equipment
(Outdoor)
         businesses, and the Industrial Segment is comprised of Engineered
Fastening and
         Infrastructure businesses. We also note that you have provided
disaggregated revenue for
         each of the two businesses in the Industrial Segment, as well as by
geographic areas for
         consolidated revenue. Further we note from your second quarter 2023
earnings call, that
         you discuss revenue by    strategic business unit performance    which
includes revenue
         trends for outdoor, hand tools, storage solutions and power tools.
Please tell us what
         consideration you gave to disclosing additional revenue information by
these businesses in
         the Tools & Outdoor segment, or other product categories, within the
notes to your
         financial statements. Refer to guidance in ASC 606-10-55-89 through
55-91 and ASC
         280-10-50-40.
Note Q. Income Taxes, page 108

6.       We note from your disclosure in Note Q, that the intra-entity asset
transfer of intellectual
         property had a significant effect on your effective tax rate in both
2021 and 2022.
         Additionally, you disclose that the increase in intangible deferred
tax assets relates to the
         intra-entity asset transfer of certain intangible assets between two
of your foreign
         subsidiaries Please tell us, and revise future filings to disclose,
the details of this IP
         transfer, including the nature of any estimates and assumptions
related to the valuation of
         this transaction.
Note S. Contingencies, page 112

7.       We note your disclosure in Note S of several environmental and other
ongoing
         contingencies. We also note that in Item 3. Legal Proceedings on page
24, you disclose
         two investigations with the SEC and/or DOJ, in which you disclose that
the Company
         does not believe that these matters will have a material impact on its
financial condition or
         results of operations, although it is possible that a loss related to
these matters may be
         incurred. In light of this potential loss contingency, it appears that
these matters should be
         included as a loss contingency in your notes to the financial
statements in accordance with
         ASC 450-20-50. As applicable, please revise future filings
accordingly.
Form 8-K furnished October 27, 2023

Exhibit 99.2 Financial statements and supporting schedules contained in Stanley
Black
& Decker, Inc.'s October 27, 2023 press release, page 8

8.       We note that your statements of operations presented on page 8 of your
earning release,
         include the presentation of an Operating Profit subtotal. In light of
the fact that this
         subtotal appears to exclude charges for asset impairment and
restructuring and potentially
 Patrick Hallinan
Stanley Black & Decker, Inc.
November 28, 2023
Page 4
         other operating expenses included in the    other-net    line item, it
does not represent a
         measure calculated in accordance with GAAP. Please remove this
subtotal from your
         statements of operations or alternatively clearly label as a Non-GAAP
measure and
         include the disclosures required by Item 10(e) of Regulation S-K.
       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 Claire Erlanger at 202-551-3301 or Melissa Gilmore at
202-551-3777 with
any questions.



FirstName LastNamePatrick Hallinan                            Sincerely,
Comapany NameStanley Black & Decker, Inc.
                                                              Division of
Corporation Finance
November 28, 2023 Page 4                                      Office of
Manufacturing
FirstName LastName