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Colfax
Corporation
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8730
Stony Point Parkway
Suite
150
Richmond,
VA 23235
USA
Tel: (804)
560-4070
Fax: (804)
560-4076
www.colfaxcorp.com
August
11, 2010
Mr. Brian
Cascio
Accounting
Branch Chief
Division
of Corporation Finance
U.S.
Securities and Exchange Commission
100 F
Street NE
Washington,
DC 20549
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RE:
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Colfax
Corporation
Form
10-K for the fiscal year ended December 31, 2009
Filed
February 25, 2010
File
No. 001-34045
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Dear Mr.
Cascio:
Colfax
Corporation (the “Company”) received the staff’s letter dated July 30, 2010,
which provided comments on the above-referenced document and our correspondence
dated July 7, 2010. References to the Company in the response refer
to Colfax Corporation and its consolidated subsidiaries. This
response letter has been filed on EDGAR.
In
connection with responding to the staff’s comments, the Company hereby
acknowledges the following:
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·
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the
Company is responsible for the adequacy and accuracy of the disclosure in
the filing;
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·
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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
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·
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the
Company 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.
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For your
convenience the staff’s comment is set forth below and is followed by the
Company’s response.
Form 10-K for the fiscal
year ended December 31, 2009
Item 8. Financial
Statements
Note 18. Commitments and
Contingencies, page 74
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1.
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We
refer to your response to prior comment 3. With respect to the
significant increase in the asbestos liability recorded in the third
quarter of 2009, in future filings, please clarify that the analysis
performed in that quarter indicated that a statistically significant
increase in the number of mesothelioma claims filings had occurred and was
expected to continue, as described in your
response.
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Response
In future
filings, the Company will clarify that the analysis performed in the third
quarter indicated that a statistically significant increase in the number of
mesothelima claims filings had occurred and was expected to
continue.
If you
have any questions or require further information, please call me at (804)
327-5668 or fax me at (804) 560-4076.
Sincerely,
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/s/
G. SCOTT FAISON
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G.
Scott Faison
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Senior
Vice President, Finance
and
Chief Financial Officer
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