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United States securities and exchange commission logo
October 21, 2022
Charles Lauber
Executive Vice President and Chief Financial Officer
A. O. Smith Corporation
11270 West Park Place
Milwaukee, Wisconsin 53224
Re: A. O. Smith
Corporation
Form 10-K for
Fiscal Year Ended December 31, 2021
Response Dated
October 11, 2022
File No. 001-00475
Dear Charles Lauber:
We have reviewed your October 11, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
September 9, 2022 letter.
Response Dated October 11, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
19
1. We note your response
to prior comment 5. Please provide us with additional detail
explaining how you
considered providing disclosure regarding reputational risks resulting
from operations or
products that produce greenhouse gas emissions to investor perception
and your ability to
obtain external financing.
Charles Lauber
FirstName
A. O. SmithLastNameCharles Lauber
Corporation
Comapany
October 21,NameA.
2022 O. Smith Corporation
October
Page 2 21, 2022 Page 2
FirstName LastName
Please contact Erin Donahue at 202-551-6063 or Ethan Horowitz at
202-551-3311 with
any questions.
Sincerely,
Division of Corporation
Finance
Office of Manufacturing