March 29, 2006

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
		Response letter dated March 1, 2006
		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, and response letter dated March 1,
2006, to disclosures relating to your contacts with countries that
have been identified as state sponsors of terrorism.  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 have reviewed your letter dated March 1, 2006.  Please clarify
whether any of your subsidiaries` direct or indirect contacts with
Iran were with the Iranian government or entities controlled by
the
Iranian government.  Describe in reasonable detail the nature of
any
such contacts and the technology, products, and/or services your
subsidiaries provided.  Advise us whether, to the best of your
knowledge, understanding or belief, any technology, products or
services your subsidiaries provided, directly or indirectly, to
the
Iranian government or state-controlled entities have military
applications.

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: 	David L. McAusland
		Executive Vice President
	Alcan, Inc.
	P.O. Box 6090
	Montreal, Quebec H3C 3A7
	Canada


		Roger Schwall
		Assistant Director
		Division of Corporation Finance
Travis Engen
Alcan, Inc.
March 29, 2006
Page 1









UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE