SIMPSON THACHER & BARTLETT LLP
425 LEXINGTON AVENUE
NEW YORK, N.Y. 10017-3954
(212) 455-2000
FACSIMILE (212) 455-2502
DIRECT DIAL NUMBER
E-MAIL ADDRESS
January 3, 2008
VIA EDGAR AND FAX
Re:
Correspondence from SEC Staff dated
December 17, 2007 regarding
ITT Corporation
Definitive 14A
Filed April 4, 2007
File No. 001-05672
Division of Corporation Finance Securities and
Exchange Commission Attention: Hanna T. Teshome, Esq. |
Dear Ms. Teshome:
On behalf of ITT Corporation (the Company), I am writing to confirm that the Securities and Exchange Commission (the SEC) will take no exception to the request by the Company in our telephone conversation yesterday for an extension from January 7, 2008 to January 28, 2008 for the Company to respond to the comments contained in the letter from the SEC staff to the Company dated December 17, 2007.
Please do not hesitate to contact me at (212) 455-2661 should you have any questions regarding this matter.
Very truly yours,
/s/ Francis C. Marinelli
Francis C. Marinelli
cc: Katleen S.
Stolar
ITT Corporation