August 28, 2006

Via U.S. Mail and Facsimile

David H. Murdock
Chairman and Chief Executive Officer
Dole Food Company, Inc.
One Dole Drive
Westlake Village, California 91362

	Re:	Dole Food Company, Inc.
		Form 10-K for the Fiscal Year Ended December 31, 2005
		Filed April 17, 2006
		File No. 1-04455

Dear Mr. Murdock:

      We have limited our review of your Form 10-K for the fiscal
year ended December 31, 2005 to disclosure relating to your
contacts
with a country that has been identified as a state sponsor of
terrorism, and we have the following comments.  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
1. We note the disclosure on page 7 of your Form 10-K that you
"source food products in...Syria."  Syria is identified as a state
sponsor of terrorism by the State Department.  Please describe to
us
in reasonable detail your past, current, and anticipated
operations
in or other contacts with Syria, whether through direct or
indirect
arrangements.  Also, describe the extent to which your dealings
have
been with the government of Syria, or entities owned or controlled
by
that government.
2. [0] Please discuss the materiality of the operations or other
contacts described in response to the foregoing comment, and
whether
those operations or contacts constitute a material investment risk
for your security holders.  You should address materiality in
quantitative terms, including the dollar amounts of any associated
revenues, assets, and liabilities.  Please also address
materiality
in terms of qualitative 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.
We note, for example, 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.  The Pennsylvania legislature has adopted a resolution
directing its Legislative Budget and Finance Committee to report
annually to the General Assembly regarding state funds invested in
companies that have ties to terrorist-sponsoring countries.  The
Missouri Investment Trust has established an equity fund for the
investment of certain state-held monies that screens out stocks of
companies that do business with U.S.-designated state sponsors of
terrorism.  Your materiality analysis should address the potential
impact of the investor sentiment evidenced by such actions
directed
toward companies having operations in, or other business contacts
with, Syria.
Your qualitative materiality analysis also should address whether
the
Syrian government, or Syrian government-controlled entities,
receive
cash or other financing in connection with your operations in
Syria.

* * * * *

      Please respond to these comments 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 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.

      Please understand that we may have additional comments after
we
review your response to our comments.  Please contact Pradip
Bhaumik,
Attorney-Advisor, at (202) 551-3333 if you have any questions
about
the comments 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

		Michael Carter
		Dole Food Company, Inc.
		Fax: (818) 879-6754



David H. Murdock
Dole Food Company, Inc.
August 28, 2006
Page 1