United States securities and exchange commission logo August 29, 2022 Renee J. Peterson Vice President, Chief Financial Officer The Toro Company 8111 Lyndale Avenue South Bloomington, Minnesota 55420-1196 Re: The Toro Company Form 10-K for the fiscal year ended October 31, 2021 Filed December 17, 2021 Form 8-K 2.02 Filed June 2, 2022 File No. 001-08649 Dear Ms. Peterson: We have completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Real Estate & Construction