Mail Stop 04-05

						May 24, 2005


via facsimile and U.S. mail

Mr. Randy J. Vest
Vice President and Controller
Kimberly-Clark Corporation
P. O. Box 619100
Dallas, Texas

	Re:	Kimberly-Clark Corporation
		Form 10-K for the year ended December 31, 2004
		Filed February 24, 2005
		File No. 001-00225

Dear Mr. Vest:

      We have reviewed the above filing and have the following
accounting comments.  Our review has been limited to your
financial
statements and the related disclosures in Management`s Discussion
and
Analysis. 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 supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
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.


Form 10-K filed on February 24, 2005

Financial Statements and Supplementary Data, page 41

      Notes to Consolidated Financial Statements, page 45

      Note 13. Synthetic Fuel Partnership, page 67

1) We note that you have evaluated your investments in two
synthetic
fuel partnerships pursuant to the requirements of FIN 46R and
concluded that although these synthetic fuel partnerships
represent
variable interests, you have determined that you are not the
primary
beneficiary of either of these VIEs.  Please address the following
comments regarding your investment in these synthetic fuel
partnerships.

i) Although you have described the nature of your involvement with
these VIEs and concluded that your loss exposure is minimal, you
have
not disclosed the amounts invested in these partnerships or the
size
of these VIEs.  Therefore, it is unclear to us whether you have
considered the cash flows from the tax credits generated by your
investments in these VIEs in your analysis leading to your
conclusion
that you are not the primary beneficiary of these entities.
Supplementally provide us the details of your analysis concluding
that you are not the primary beneficiary that addresses the
following, without limitation.

(a) Confirm to us that you included the cash flows from your share
of
the expected tax credits along with your share of the expected
operating losses generated by these VIEs.

(b) Provide us with a summary of the total expected cash flows
from
each of these synthetic fuel partnerships detailing your share and
other investor(s) share(s).  Detail for us any differences between
the cash flows inuring to you and the other investors to the
extent
they differ from ownership percentages.

(c) Confirm to us that there are no other standing agreements
between
you and the other investors which impact the determination of the
expected losses and tax credits generated from these VIEs.

	We may have further comment.

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
amendments to expedite our review.  Please furnish a cover letter
with your amendments that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendments and
responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 comments, 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.

      You may contact William Choi at (202) 551-3716 or Jill Davis
at
(202) 551-3683 if you have questions regarding comments on the
financial statements and related matters.  Direct any other
questions
to the undersigned at (202) 551-3740.  Direct all correspondence
to
the following ZIP code:  20549-0405.

							Sincerely,



							H. Roger Schwall
							Assistant Director


Randy J. Vest
Kimberly-Clark Corporation
May 24, 2005
page 3




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE