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          [DAVIS POLK & WARDWELL LETTERHEAD]

                                                                                                                September
                    22, 2005

          Re:
           Canon Inc. — Form
                         20-F for the year ended December 31, 2004

           (File No. 0-15122)

 Ms. Kristin Lochhead

     United
          States Securities and Exchange Commission

     Division of Corporate Finance

     Washington, D.C. 20549

Dear Ms. Lochhead:
      As requested, we are submitting
          the attached letter, dated September 20, 2005 via EDGAR, as U.S. counsel
          to Canon Inc.

          Sincerely yours,

          /s/ Theodore A. Paradise

          Theodore A. Paradise

          [DAVIS POLK & WARDWELL LETTERHEAD]

          By facsimile and e-mail

                                                                                                                September
                    20, 2005

          Re:
           Canon Inc. — Form
                         20-F for the year ended December 31, 2004

           (File No. 0-15122)

Ms. Kristin Lochhead

United States Securities and Exchange Commission

Division of Corporate Finance

Washington, D.C. 20549

 Dear Ms. Lochhead:

      We are acting as U.S. counsel
          to Canon Inc. (“Canon”). I am responding to your voicemail
          of September 19, 2005, relating to Canon’s letter, dated and filed
          via EDGAR on August 31, 2005 (the “Response Letter”), submitted
          in response to the comment letter of the staff of the United States
          Securities and Exchange Commission (the “Commission”) dated
          July 1, 2005 relating to Canon’s annual report on Form 20-F for
          the fiscal year ended December 31, 2004 (the “2004 Form 20-F”).

      You inquired as to the consistency
          between Note 1(c) to Canon’s financial statements for the fiscal
          year ended December 31, 2004 included in the 2004 Form 20-F and Canon’s
          response to Comment 4 of the Commission.

      Note 1(c) to Canon’s
          financial statements for the fiscal year ended December 31, 2004 states:

       “(c)
Principles of Consolidation

           The consolidated financial statements include the accounts
                              of the Company, its majority owned subsidiaries and those variable
                              interest entities where the Company is the primary beneficiary under
                              FASB Interpretation No. 46 (revised December 2003) (“FIN 46R”), “Consolidation
                              of Variable Interest Entities.” All

           Ms. Kristin Lochhead
           3
           September 20, 2005

           significant intercompany balances and transactions have
                              been eliminated.”

      As set forth in the Response
          Letter under “Response to Comment 4”, there are two variable
          interest entities of which Canon has deemed itself to be the primary
          beneficiary. However, Canon determined for the reasons described in
          the Response Letter not to consolidate such entities in its financial
          statements for the fiscal year ended December 31, 2004.

      Canon has informed us that
          it currently intends to consolidate SED Inc. (“SED”) in Canon’s
          consolidated financial statements for the fiscal year ending December
          31, 2005 (“Fiscal 2005”). Canon is also in the process of
          determining whether to consolidate Image Financial Services, Inc. (“IFS”)
          in Canon’s consolidated financial statements for Fiscal 2005.
          Canon recognizes that it will need to draft its note on principles
          of consolidation in its financial statements for Fiscal 2005 to reflect
          accurately its principles of consolidation relating to variable interest
          entities, and intends to do so.

      If you have any questions
          about this letter or any further comments on Canon’s 2004 Form
          20-F, please do not hesitate to contact me (Tel: +81-3-5561-4430; Fax:
          +81-3-5561-4425; E-mail: theodore.paradise@dpw.com).

          Sincerely yours,

          /s/ Theodore A. Paradise

          Theodore A. Paradise

          cc:
          Mr. Katsuhito Yanagibashi

          Canon Inc.

          Mr. Alan L. Forman

          Ernst & Young ShinNihon