Acme United Corporation
60 Round Hill Road
Fairfield, CT 06824
March 20, 2012
John M. Hartz, Senior Assistant Chief Accountant
Securities and Exchange Commission
Washington, D.C. 20549-0404
RE: Acme United Corporation
Dear Mr. Hartz:
This letter is in response to your February 15, 2012 comment letter relating to our Form 10-K for the year ended December 31, 2010. Your comment accompanied by our response is provided below.
Form 10-K for the year ended December 31, 2010
10. Segment Information, page 28
| 1. | We have read your response to comment 1 in our letter dated December 2, 2011. Please upload as correspondence to Edgar the content of the December 12, 2011 email referenced in your response. |
| Response | |
| In accordance with recent discussions with the staff, the Company is separately submitting the subject information to you, together with a request for confidential treatment, pursuant to 17 C.F.R. 200.83 (“Rule 83”). As required by Rule 83(b)(3), the Company is also sending a copy of the request for confidential treatment (but not the information for which confidential treatment is requested) to the Commission’s Office of FOIA Services. |
In connection with our response to the Staff's comments, Acme United Corporation hereby acknowledges that:
| o |
Acme United Corporation is responsible for the adequacy and accuracy of the disclosures in the filing;
|
| o | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| o | Acme United Corporation 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. |
Sincerely,
/s/ Paul G. Driscoll
Paul G. Driscoll
Vice President and Chief Financial Officer