HNI Corporation 408 East
Second Street, Muscatine, Iowa 52761, Tel 563 272 7400, Fax 563 272 7347,
www.hnicorp.com
June 16,
2009|
U.S.
Securities and Exchange
Commission VIA
EDGAR AND FACSIMILE
Division
of Corporation Finance
Mail
Stop 7010
100
F Street, N.E.
Washington,
D.C. 20549
Attn: Sherry
Haywood, Staff Attorney
Re: HNI
Corporation
Registration Statement on Form
S-3
File No.
333-157578
Ladies
and Gentlemen:
On
behalf of HNI Corporation ("HNI") and pursuant to Rule 461 under the
Securities Act of 1933, the undersigned hereby requests the effective date
of the above-referenced Registration Statement on Form S-3 be accelerated
to 12:00 p.m., Washington, D.C. time, on Thursday, June 18, 2009, or as
soon thereafter as practicable. HNI hereby acknowledges
that:
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should
the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from
taking any action with respect to the filing;
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the
action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the company
from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and
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the
company may not assert staff comments and the declaration of effectiveness
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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U.
S. Securities and Exchange Commission
Page 2
June 16, 2009
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Please
contact me at (563) 272-4919 if you have any questions regarding the
foregoing request.
Sincerely,
 Steven
M. Bradford
Vice
President, General Counsel and Secretary
cc:
Koby Kreinbring, Senior Counsel – HNI Corporation
Joseph P. Richardson, Esq.
– Squire, Sanders & Dempsey L.L.P.
Matthew M. Holman, Esq. –
Squire, Sanders & Dempsey L.L.P.
Facsimile: (202)
772-9177 |