February 15, 2005

Via U.S. Mail and Facsimile

Travis Engen
Chief Executive Officer
Alcan, Inc.
1188 Sherbrooke Street West
Montreal, Quebec, Canada H3A 3G2


RE:		Alcan, Inc.
		Form 10-K for the fiscal year ended December 31, 2004
		File No. 1-3677

Dear Mr. Engen:

      We have limited our review of your Form 10-K for the fiscal
year ended December 31, 2004, to disclosures relating to your
contacts with countries that have been identified as state
sponsors
of terrorism, and will make no further review of those forms.  Our
review with respect to this issue does not preclude further review
by
the Assistant Director group with respect to other issues.  At
this
juncture, we are asking you to provide us with supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. After
reviewing
this information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


General -

We note that in Exhibit 21 to your 10-K for the fiscal year ended
December 31, 2000, you list as a subsidiary Swiss Aluminum Iran
LTD,
which you describe as being organized under the laws of Iran.  You
do
not mention this subsidiary in lists of subsidiaries filed as
exhibits to your subsequent 10-Ks.  We also note news reports that
a
company you acquired, Pechiney, bid for the engineering,
procurement
and construction contract to build a new aluminum refinery in
Iran.
In light of the fact that Iran has been identified by the U.S.
State
Department as a state sponsor of terrorism, and is subject to
economic sanctions administered by the U.S. Treasury Department`s
Office of Foreign Assets Control,  please describe for us the
extent
and nature of your past, current, and anticipated contacts with
Iran;
advise us of the materiality to you of your contacts with Iran;
and
advise us of your view as to whether those contacts constitute a
material investment risk for your security holders.  In preparing
your response please consider that evaluations of materiality
should
not be based solely on quantitative factors, but should include
consideration of all factors that a reasonable investor would deem
important in making an investment decision, including the
potential
impact of corporate activities upon a company`s reputation and
share
value.  In this regard, we note that Arizona and Louisiana have
adopted legislation requiring their state retirement systems to
prepare reports regarding state pension fund assets invested in,
and/or permitting divestment of state pension fund assets from,
companies that do business with countries identified as state
sponsors of terrorism.  Your materiality analysis should address
the
potential impact of the investor sentiment evidenced by these
actions.


Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.



								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk




cc: 	Roger Schwall
		Assistant Director
		Division of Corporation Finance