January 10, 2006

Room 7010

Raymond J. Seabrook
Sr. Vice President and Chief Financial Officer
Ball Corporation
10 Longs Peak Drive, PO Box  5000
Broomfield, Colorado 80021-2510

Re:	Ball Corporation
	Form 10-K for Fiscal Year Ended December 31, 2004
Forms 10-Q for the Fiscal Quarters Ended April 3, 2005, July 3,
2005,
and October 2, 2005
	File No. 001-07349

Dear Mr. Seabrook:

      We have reviewed your response to our letter dated November
22,
2005 in connection with our review of the above referenced filings
and have the following comments.  Please note that we have limited
our review to the matters addressed in the comments below.  We may
ask you to provide us with supplemental information so we may
better
understand your disclosure.  Please be as detailed as necessary in
your explanation.  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 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 10-K for the year ended December 31, 2004

2. Business Segment Information

1. With regards to your prior comment 1, we note that North
American
Metal Food Containers, North American Metal Beverage Containers
and
North American Plastic containers are each operating segments
which
you aggregate into a single reporting segment. You have provided
us
with some analysis concerning the EBIT margins of these operating
segments. However without the underlying information it is
difficult
for us to gain an appropriate understanding of their comparative
operations.
Please provide for us the financial information that is provided
to
the CODM (as a group) which shows the EBIT margins for each
operating
segment for each of the last 3 years, including international and
Aerospace and Technologies. In addition, please explain to us the
operating structure of Aerospace and Technologies. We assume that
there are operating segments within that reportable segment as
well.

       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.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
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 any amendment and your responses to our comments.

	You may contact Melissa Rocha at (202) 551-3854 or me at
(202)
551-3689 if you have questions regarding comments on the financial
statements and related matters.


Sincerely,


John Hartz
Senior Assistant Chief Accountant
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Raymond J. Seabrook
Ball Corporation
January 10, 2006
Page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
   CORPORATION FINANCE