Mail Stop 7010

      May 3, 2006

Mr. Gregory N. Miller
Hillenbrand Industries, Inc.
1069 State Route 46 East
Batesville, Indiana 47006-8835

      Re:	Hillenbrand Industries, Inc.
		Form 10-K for the year ended September 30, 2005
		Form 10-Q for the period ended December 31, 2005
      Filed December 23, 2005
      File No. 1-6651

Dear Mr. Miller:

      We have reviewed your response letter dated April 25, 2006
and
have the following additional comments.  Where indicated, we think
you should revise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our
comment
is inapplicable or a revision is unnecessary.  Please be as
detailed
as necessary in your explanation.  In some of our comments, we may
ask you to provide us with information so we may better understand
your disclosure.  After reviewing this information, we may raise
additional comments.

FORM 10-K FOR THE YEAR ENDED SEPTEMBER 30, 2005

Note 17 - Commitments and Contingencies, page 110

1. We read your response to comment 4 from our previous comment
letter dated March 28, 2006.  Please confirm to us that if you
change
or discontinue those discounting practices currently in effect
that
you refer to as "company initiated discounting practices", or if
it
is probable that such a change will be made, and if such a change
has
or is reasonably expected to have a material favorable or
unfavorable
impact on your results, you will disclose this fact and quantify
the
impact of this change in your MD&A analysis.  In this regard,
please
note that we are not asking you to disclose the details of any new
discounting practices; rather, we are asking you to disclose the
fact
that a material change in your discounting practices occurred and
to
quantify the impact of that change.  Refer to Item 303(a)(3)(ii)
of
Regulation S-K.



FORM 10-Q FOR THE PERIOD ENDED DECEMBER 31, 2005

MD&A - Results of Operations, page 27

2. We read your response to comment 5 from our previous comment
letter dated March 28, 2006.  We note that the management reports
provided to us display discrete financial information for sales
and
rentals within each of your current reportable segments.  We would
normally consider this level of detail in your management reports
to
be an indication that sales and rentals could potentially be
considered separate reportable segments.  However, we also note
that
your analysis of results of operations has historically separately
analyzed your gross margins derived from sales and those derived
from
rentals to provide your investors with insight into the differing
margins from these businesses.  We believe that management is in
the
best position to determine your reportable segments under SFAS
131.
We note your statement that you remain in a period of transition,
and
we urge you to continue to consider the requirements of SFAS 131
as
you determine your segments going forward.  In light of the above,
we
have no further comments concerning your reportable segments at
this
time, provided that you continue to disclose disaggregated
information for sales and rentals within each of your segments in
your analysis of results of operations.

3. We note that your most recent periodic filing continued to
analyze
your results of operations by operating company (i.e. Health Care
and
Funeral Services).  In future filings, please confirm to us that
you
will revise this disclosure to provide separate analysis of
results
of operations for each of your segments.  For example, your
analysis
at December 31, 2005 should have separately analyzed the results
of
NASSM, International, Home Care & Surgical, the functional and
corporate costs of Hill-Rom, and Batesville Casket.  Refer to Item
303(a) of Regulation S-K and our Release 33-8350 available on our
website at www.sec.gov/rules/interp/33-8350.htm.


*	*	*


		Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please
provide
us with a response letter that keys your responses to our comments
and provides any requested information.  Detailed letters greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your responses to our comments.



      If you have any questions regarding these comments, please
direct them to Jennifer Thompson, Staff Accountant, at (202) 551-
3737
or, in her absence, to John Hartz, Senior Assistant Chief
Accountant,
at (202) 551-3689 or the undersigned at (202) 551-3768.


      Sincerely,



      John Cash
      Accounting Branch Chief

Mr. Gregory N. Miller
Hillenbrand Industries, Inc.
May 3, 2006
Page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE