April 1, 2020

Scott C. Morrison
Chief Financial Officer
Ball Corporation
10 Longs Peak Drive
P.O. Box 5000
Broomfield, Colorado 80021-2510

       Re: Ball Corporation
           Form 10-K for the Year Ended December 31, 2019
           Filed February 19, 2020
           File No. 001-07349

Dear Mr. Morrison:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Year Ended December 31, 2019

Financial Condition, Liquidity and Capital Resources
Cash Flows and Capital Expenditures, page 28

1.    Although the header indicates a discussion of cash flows and capital
expenditures, we note
      no discussion of the changes in cash flows from investing and financing
activities. Please
      revise to include detail of the nature of the cash flows in investing and
financing activities
      including changes from year to year.
 Scott C. Morrison
Ball Corporation
April 1, 2020
Page 2
Financial Statements
Notes to the Consolidated Financial Statements
1. Critical and Significant Accounting Policies
Significant Accounting Policies
Inventories, page 45

2.       We note your disclosure that inventories are carried at the lower of
cost or market. Please
         tell us how this is consistent with ASC 330-10-35-1B which indicates
that inventories
         should be valued at the lower of cost or net realizable value.
        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.

       You may contact Heather Clark at 202-551-3624 or John Cash at
202-551-3768 with any
questions.



FirstName LastNameScott C. Morrison                            Sincerely,
Comapany NameBall Corporation
                                                               Division of
Corporation Finance
April 1, 2020 Page 2                                           Office of
Manufacturing
FirstName LastName