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                             June 2, 2020

       John Murphy
       Chief Financial Officer
       COCA COLA CO
       One Coca-Cola Plaza
       Atlanta, GA 30313

                                                        Re: COCA COLA CO
                                                            Form 10-K for
Fiscal Year Ended December 31, 2019
                                                            Filed February 24,
2020
                                                            Form 10-Q for
Fiscal Quarter Ended March 27, 2020
                                                            Filed April 24,
2020
                                                            File No. 1-02217

       Dear Mr. Murphy:

              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 Fiscal Year Ended December 31, 2019

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Liquidity, Capital Resources and Financial Position
       Cash Flow from Operating Activities, page 58

   1.                                                   We note from your
disclosures that accounts payable increased roughly $1.1 billion in
                                                        2019 due to the
extension of payment terms with your suppliers. We further note from
                                                        external sources that
it appears you have in place a supply chain finance program. To the
                                                        extent supply chain
finance arrangements are reasonably likely to affect your liquidity in
                                                        the future, please
disclose the following:
                                                          The impact the
arrangements have on operating cash flows;
                                                          The material and
relevant terms of the arrangements;
                                                          The general risks and
benefits of the arrangements;
 John Murphy
COCA COLA CO
June 2, 2020
Page 2
          Any guarantees provided by subsidiaries and/or the parent;
          Any plans to further extend terms to suppliers;
          Any factors that may limit your ability to continue using similar
arrangements to
          further improve operating cash flows; and
        Trends and uncertainties related to the extension of payment terms
under the
          arrangements.
      In addition, please consider disclosing and discussing changes in your
accounts payable
      days outstanding to provide investor's with a metric of how supply chain
finance
      arrangements impact your working capital.
Form 10-Q for Fiscal Quarter Ended March 27, 2020

Risk Factors
The COVID-19 pandemic has had, and we expect will have, certain negative
impacts on our
business..., page 39

2.    We note your disclosure states you may be required to write off the
unamortized balances
      of advanced funding provided to customers that permanently close as a
result of the
      pandemic. We also note in your disclosures that you provide support for
infrastructure
      programs to your customers. Please clarify for us, and disclose in your
filings, the nature
      of these arrangements and quantify the amounts capitalized on your
balance sheets for
      advanced funding and other customer support programs as of each balance
sheet date
      presented.
        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 Kevin Stertzel, Staff Accountant at (202) 551-3723 or
Anne
McConnell, Staff Accountant at (202) 551-3709 if you have questions regarding
comments on
the financial statements and related matters.



                                                           Sincerely,
FirstName LastNameJohn Murphy
                                                           Division of
Corporation Finance
Comapany NameCOCA COLA CO
                                                           Office of
Manufacturing
June 2, 2020 Page 2
cc:       Mark Randazza CAO
FirstName LastName