Mail Stop 3561

      							June 30, 2005




Mr. Alan D. Horn
Vice President, Finance and Chief Financial Officer
Rogers Communications Inc.
333 Bloor Street East
10th Floor
Toronto, Ontario  M4W 1G9

	Re:	Rogers Communications Inc.
      Form 40-F for Fiscal Year Ended December 31, 2004
		Filed March 18, 2005
		File No. 1-10805

Dear Mr. Horn:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise your documents 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 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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.


Form 40-F for Fiscal Year Ended December 31, 2004

Disclosure Controls and Procedures

1. We note your statement that your chief executive officer and
chief
financial officer "concluded that as of the Evaluation Date such
disclosure controls and procedures were reasonably designed to
ensure
the information required to be disclosed by the Company in reports
it
files or submits under the Exchange Act is recorded, processed,
summarized and reported within the time periods specified in the
rules and forms of the Securities and Exchange Commission."  It
does
not appear that your certifying officers have reached a conclusion
that your disclosure controls and procedures are effective.
Please
revise to address your officers` conclusions regarding the
effectiveness of your disclosure controls and procedures.

2. We note the statement that "there have been any significant
changes in internal controls..."  Item 308(c) of Regulation S-K
requires disclosure of any changes, not just significant changes,
in
internal controls over financial reporting that would have a
material
effect and occurred during the last fiscal quarter.  Please
revise.

Exhibit Index

Exhibit 99.2

3. Revise to indicate that the Form 6-K is deemed to be filed for
purposes of section 18 of the Securities Exchange Act of 1934.


*    *    *    *

      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
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
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
a 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 Kathleen Kerrigan, Staff Accountant, at
(202)
551-3369 or Michele Anderson, Legal Branch Chief, at (202) 551-
3833
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 551-3810 with any
other questions.

								Sincerely,



								Larry Spirgel
								Assistant Director



Mr. Alan D. Horn
Rogers Communications Inc.
June 30, 2005
Page 3