Mail Stop 04-05

						August 19, 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

      Response letter dated June 7, 2005
		File No. 001-00225

Dear Mr. Vest:

      We have reviewed your response letter dated June 7, 2005 and
have the following accounting comments.  Please address both of
your
synthetic fuel partnerships in response to our comments.  Our
review
has been limited to your financial statements and the related
disclosures in Management`s Discussion and Analysis.  Please
provide
a written response to our comments.  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 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. Tell us how you calculated the Total Project Present Values
presented in Exhibits A and B.  Specifically, address the
following:

* Detail for us the assumptions regarding production volume, sales
price of the synthetic fuel produced, revenue inflation and cost
inflation associated with the base outcomes used for your Monte
Carlo
analyses.

* Detail for us the same assumptions associated with the expected
average outcomes from your Monte Carlo analyses.

* Provide us the details of how revenues, production costs, other
operating costs, operating losses, Section 29 tax credits and tax
benefits of operating losses are allocated among the partners to
arrive at the probability weighted present value of cash flows and
the expected losses and / or expected residual returns.  Provide
us
an example of such an allocation for the average probability
weighted
present value values of cash flows you have presented in Exhibits
A
and B.

* Clarify how you addressed the scheduled expiration of the
Section
29 tax credits in your assumptions.

2. Tell us the total amount of revenues, production costs,
operating
losses and tax credits and the corresponding amounts of operating
losses and tax credits allocated to each ownership interest for
both
of your synthetic fuel partnerships for the years ended 2003 and
2004.  Quantify for us any payments made directly to the
owner/manager outside of the partnership agreements in each of
these
years.

3. We note in footnote 3 of your response you indicate that in
late
2004 you refined the method used to perform the cash flow analysis
of
one of your synthetic fuel partnerships concluding that payments
made
to the owner/manager outside of the operation of the partnership
entity should be included in the cash flow analysis.  Tell us the
following regarding these payments:

* Tell us what these payments represented.

* Tell us if these additional payments impacted the allocation of
operating losses and tax credits for the partnership, and if so,
explain to us how the allocation changed.

* Confirm for us that you are not required to make similar
payments
to the owner/manager of Partnership 2.

4. Tell us if any guarantees or other agreements exist outside of
the
partnership agreements.  If so, please provide us with the
details.

5. You indicate that your expected share of losses and expected
residual returns is less than your ownership due to contractual
provisions which limit your share of production costs to a fixed
dollar amount per dollar of tax credit generated.  Tell us if your
fixed share of production costs is subject to any conditions and
whether a change in any condition(s) would cause an adjustment to
the
fixed amount.

6. You indicate that the amounts of cash funding for your
partnerships represented your share of the operating losses of
these
entities.  Confirm for us that you did not provide any
consideration
for your minority interests in both these partnerships.

7. Tell us if any of the other investors or the manager of the two
synthetic fuel partnerships is a related party as that term is
defined in SFAS 57 and whether certain other parties are acting as
de
facto agents or de facto principals as defined in paragraph 16 of
FIN
46(R).

Closing Comments

      Please 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 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.

      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
August 19, 2005
page 4




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

         DIVISION OF
CORPORATION FINANCE