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corresp

March 23, 2007

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20002

Facsimile: (202) 772-9213

    Attention:

    Ms. Cecilia D. Blye, Chief

    Office of Global Security Risk

    Re:

    Avery Dennison Corporation

    Form 10-K for the Fiscal Year ended December 31, 2005

    Filed March 15, 2006

    File No. 1-7685

Ladies and Gentlemen:

     In connection with the comments contained in the December 14, 2006 letter (the “Comment
Letter”) from the staff of the Commission (the “Staff”) to Mr. Dean A. Scarborough, President and
Chief Executive Officer of Avery Dennison Corporation (for these purposes, including all of its
subsidiaries worldwide, the “Company”), the Company’s responses to the Staff’s comments are
presented below.

For your convenience, we have set forth the comments contained in the Staff’s Comment Letter,
followed by our responses.

Form 10-K for the Year Ended December 31, 2005

General

    1.

    Staff Comment: We note that your website lists addresses and contact
information for resellers in Kish Island, Iran and Damascus, Syria. We also note several
“Instructional Bulletins” for the durability of certain company products that list, among
other countries and U.S. states, Cuba, Iran, North Korea, Syria and Sudan. Each of these
countries is identified as a state sponsor of terrorism by the State Department and subject to
sanctions administered by the Commerce Department’s Bureau of Industry and Security and the
Treasury Department’s Office of Foreign Assets Control. We note that the Form 10-K does not
contain any information relating to operations in or contacts with any of these countries.
Please describe your operations in and contacts with these countries, if any, and discuss
their materiality to you in light of their status as state sponsors of terrorism. Please also
discuss whether the operations or contacts constitute a material investment risk to your
security

Securities and Exchange Commission

March 23, 2007

     holders. Your response should describe your current, historical and anticipated operations and
contacts with Cuba, Iran, North Korea, Sudan and Syria, including through subsidiaries,
affiliates, reseller offices, agents other direct and indirect arrangements.

The Company does not have operations in Cuba, Iran, North Korea, Syria or Sudan. Based on a
review of information provided by the Company’s subsidiaries, certain foreign subsidiaries had de
minimis sales to certain distributors and companies in Iran and Syria during 2004, 2005 and 2006,
as follows:

Office and Consumer Products segment:

One of the Company’s subsidiaries in Italy sold office labels (die-cut labels and mailing labels)
to a distributor in Syria. These products were manufactured in Europe and contained less than 10%
U.S. content. Sales were approximately U.S. $28,000 in 2004, and U.S. $19,000 in 2005.
There were no sales in 2006.

Retail Information Services segment:

One of the Company’s subsidiaries in Europe sold small desktop printers and accessories used to
print information, including barcodes on labels, to a distributor in Syria and to a company in
Iran. These products were manufactured in Europe and contained less than 10% U.S. content. Sales
were approximately U.S. $11,000, U.S. $4,000 and U.S. $19,000 in 2004, 2005 and 2006,
respectively.

Pressure-sensitive Materials segment:

Roll Materials business

One of the Company’s subsidiaries in South Africa sold soap stiffener board that a company in Iran
used in its soap packaging product. The stiffener board was sourced from a South African supplier
and contained less than 10% U.S. content. Sales were approximately U.S. $72,000 in 2005 and
$123,000 in 2006. There have been no sales since March 2006.

Additionally, one of the Company’s subsidiaries in Europe has sold to several companies in Iran and
Syria pressure-sensitive label materials to make labels that are typically used to label food,
health and beauty products. These materials were manufactured in Europe and contained less than
10% U.S. content. Sales to Iran and Syria were approximately U.S. $524,000, U.S.
$710,000 and U.S. $299,000 during 2004, 2005 and 2006, respectively. There have been no sales
since September 2006.

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Securities and Exchange Commission

March 23, 2007

Graphics and reflective businesses

One of the Company’s subsidiaries in Europe sold graphic materials to Iran and Syria during 2004 to
2006, including pressure-sensitive materials for digital and offset printers, and for screen
printers and sign makers. These products were manufactured in Europe and contained less than 10%
U.S. content. Sales to Iran and Syria were approximately U.S. $635,000, U.S. $16,000 and
U.S. $79,000 during 2004, 2005 and 2006, respectively.

The Company’s reflective products division is currently reviewing materials sold during the period
from 2004 to 2006. It appears that some U.S.-manufactured material
for traffic signs and license plates was sold by a European
subsidiary out of European inventory and ultimately destined for Syria. The reflective products
division has made an initial voluntary disclosure to the Office of Export Enforcement of the U.S. Department
of Commerce that it is reviewing this information for potential violations of applicable export
restrictions. Affected sales for these transactions during the period
from 2004 through 2006 were approximately U.S. $350,000.

Other specialty converting businesses:

The Company’s specialty tape business in Europe sold materials to secure diapers (diaper tapes) for
baby/adult diapers to customers in Iran and Syria from 2004 to 2006. These products were
manufactured in Europe and contained less than 10% U.S. content. Sales to Iran and Syria totaled approximately U.S. $4.9 million, U.S. $3.9 million and U.S. $3.5 million during
2004, 2005 and 2006, respectively.

With the possible exception of the reflective products sold by a European subsidiary out of
European inventory to Syria, the Company believes that the above transactions were permissible.

    2.

    Staff Comment: Your materiality analysis should address materiality in quantitative
terms, including the approximate dollar amount of revenues, assets and liabilities associated
with each of the countries individually and in the aggregate. Please address materiality in
terms of qualitative factors that a reasonable investor would deem important in making an
investment decision, including the potential impact of corporate activities upon your
reputation and share value.

    We note, for example, that Arizona and Louisiana have adopted legislation requiring their
state retirement systems to prepare reports regarding state pension fund assets invested in,
and/or permitting divestment of state pension fund assets from, companies that do business with
countries identified as state sponsors of terrorism. The Pennsylvania legislature has adopted a
resolution directing its Legislative Budget and Finance Committee to report annually to the
General Assembly regarding state funds invested in companies that have ties to
terrorist-sponsoring countries. The Missouri Investment Trust has established an equity

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Securities and Exchange Commission

March 23, 2007

    fund for the investment of certain state-held monies that screens out stocks of companies that
do business with U.S.-designated state sponsors of terrorism. Illinois, Oregon, New Jersey and
other states have adopted, and additional states in, and/requiring the divestment of certain
assets from, companies that do business with Sudan. Harvard University, Stanford University,
Dartmouth College, the University of California and other academic institutions have adopted
policies prohibiting investment in, and/or requiring divestment from, companies that do business
with Sudan. Florida requires issuers to disclose in their prospectuses any business contacts
with Cuba or persons located in Cuba. Your materiality analysis should address the potential
impact of the investor sentiment evidenced by the referenced legislative and university actions
directed toward companies with operations associated with Cuba, Iran, North Korea, Sudan and
Syria.

The Company refers the Staff to the Company’s response to comment No. 1. The Company believes that
these sales to distributors and companies in Iran and Syria are not material to the Company and do
not constitute a material investment risk to the Company’s investors. In assessing materiality of
such sales, the Company considered materiality based on quantitative factors, as well as
qualitative factors that a reasonable investor would consider important in making an investment
decision in the Company’s securities, including the potential impact of the Company’s reputation
and share value.

The Company understands that certain legislation and guidelines referred to by the Staff have been
adopted by certain states and organizations that permit or require divestment from, or reporting of
interests in, companies that do business with certain U.S.-designated state sponsors of terrorism.
The Company is not aware that such legislation has, to date, had a
material impact on the Company’s reputation or share value.

    3.

    Staff Comment: Please also address the impact of your regulatory compliance
programs, such as programs designed to prevent terrorism funding, which cover operations and
contacts associated with these countries, and any internal risk assessment undertaken in
connection with business in Iran.

The Company’s Code of Business Principles provides for compliance with applicable legal
requirements, including trade sanction regulations. The Company has
initiated a review of its
policies, procedures, and practices relating to compliance with export control policies, including
any transactions relating to countries that have been listed as state sponsors of terrorism, with a
view to enhancing controls pertaining to compliance with applicable U.S. legal requirements.

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Securities and Exchange Commission

March 23, 2007

    4.

    Staff Comment: Your qualitative materiality analysis also should address whether,
and the extent to which, the governments of the referenced countries, or entities controlled
by those governments, receive cash or act as intermediaries in connection with your
operations.

To the best of our knowledge, the Company’s sales referred to above have not involved the receipt
of cash by governments or entities controlled by governments of any of the countries referenced,
nor have such governments or entities acted as intermediaries in connection with such sales.

    5.

    Staff Comment: Please address the applicability to your Iran-related activities,
including any direct or indirect payments to the Iranian government, of Section 5(b) of the
Iran Sanction Act of 1996, as modified by the Iran Freedom Support Act on September 30, 2006.

To the best of our knowledge, our products are unrelated to the production or use of weapons of
mass destruction or other weapons systems.

In addition, the Company acknowledges that:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure in the
filing;

    •

    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.

We appreciate the opportunity to respond to your comments. If you have any questions with respect
to this letter or if you require additional information, please do not hesitate to contact Thomas
W. Dobson of Latham & Watkins at (213) 485-1234 or the undersigned at (626) 304-2000.

    Sincerely,

    /s/ Mitchell R. Butier

    Mitchell R. Butier

    Vice President and Controller

    cc:

    Barbara Jacobs, Assistant Director, Division of Corporation Finance

    James Lopez, Office of Global Security Risk

    Daniel R. O’Bryant

    Thomas W. Dobson, Esq.

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