| Re: | Bowne & Co., Inc. Form 10-K Filed March 2, 2010 Amendment No. 1 to Form 10-K Filed April 20, 2010 File No. 001-05842 |
| 1. | We note your response to our prior comment number 7 and reissue. In particular, if you wish to argue that it is appropriate to omit performance targets pursuant to Instruction 4 to Item 402(b) of Regulation S-K, please provide your analysis at this time. The supplemental analysis should be based upon the 2009 10-K. In addition, supplementally advise us whether the companys targets for the fiscal year ended December 31, 2010 are expected to be materially different from those of December 31, 2009. To the extent that it is appropriate to omit specific targets, please advise us of the |
| disclosure that the company will provide pursuant to Instruction 4 to Item 402(b) of Regulation S-K. | |||
| Response: As requested in the letter received by the Company from the Staff dated August 18, 2010, the Company confirms that, to the extent the Company uses the same quantifiable measures of operating performance that it used in the fiscal year ended December 31, 2009 or other performance targets that would not result in competitive harm, the Company will, in future filings, quantify all Company-wide performance targets used to set performance based compensation, including with respect to the Company-wide performance targets used for the fiscal year ended December 31, 2010. The Company does not wish to make the argument that it is appropriate to omit the quantifiable measures of operating performance used for either fiscal year 2009 or fiscal year 2010. |