March 22, 2005


via facsimile and U.S. mail

Mr. J.W.Stewart
Chief Executive Officer
BJ Services Company
5500 Northwest Central Drive
Houston, Texas 77092


	Re:	BJ Services Company
		Form 10-K, Filed January 26, 2005
		Form 10-Q, Filed February 9, 2005
		File No. 1-10570

Dear Mr. Stewart:

      We have reviewed the above filings and have the following
accounting comments.  We have limited our review to the areas
commented on below.  Where indicated, we think you should revise
your
document 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 supplemental 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended September 30, 2004

Note 16. Subsequent Event, page 76

1. We understand from your disclosure that during the fiscal year
ended September 30, 2004 you recorded $12.2 million to "Other
Income"
($11.3 million after taxes) based on the determination that,
during
the course of a review of the Asia Pacific Region`s balance sheet,
excess liabilities had accumulated over a period of years.
Explain
to us in further detail the nature of these adjustments, and tell
us
why you believe the adjustments are properly recorded as a
component
of "Other Income."  In addition, we note your disclosure that
"[you]
believe the amounts identified were not quantitatively or
qualitatively material to the financial statements.  As such,
[you]
have recorded the correction of these amounts in fiscal 2004 since
they are not individually or in the aggregate, material to the
prior
periods or the current year."  Please provide us with your
materiality analysis to support your accounting treatment of this
correction.

2. We note that during the quarter ended December 31, 2004 you
received a repayment of $9 million from the Asia Pacific Region
Controller related to misappropriated Company funds and that you
recorded the amount as "Other Income".  We understand that you
believe no restatement for the misappropriated funds is required
because they were recorded as an expense in the Consolidated
Statement of Operations in prior periods.  Because the related
expenses reported in prior periods were not valid expenses of the
Company, this explanation does not appear to adequately support a
decision not to restate.  To the extent that you discuss this in
future filings, please revise your disclosure to more clearly
support
your accounting treatment of the misappropriated funds repayment.
In
your revised disclosure, indicate the extent to which materiality
contributed to your decision.

Closing Comments

      As appropriate, 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 your disclosure
revisions to expedite our review.  Please furnish a cover letter
that
keys your responses to our comments and provides any requested
supplemental information.  Detailed cover letters greatly
facilitate
our review.  Please file your cover letter on EDGAR.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 filing; 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 Regina Balderas, Staff Accountant, at (202)
942-7768 or Jenifer Gallagher, Senior Staff Accountant, at (202)
942-
1923 if you have questions regarding comments on the financial
statements and related matters.  Direct questions relating to all
other disclosure issues to the undersigned at (202) 942-1870.
Direct
all correspondence to the following ZIP code:  20549-0405.

							Sincerely,



							H. Roger Schwall
							Assistant Director


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BJ Services Company
March 22, 2005
page 3




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

         DIVISION OF
CORPORATION FINANCE