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[CANON INC. LETTERHEAD]

          October
                              12, 2005

     Mr. Brian Cascio

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

          Re:
          Canon, Inc.

     Form 20-F for the year
                    ended December 31, 2004

               Filed June 16, 2005

               File No. 0-15122

     Dear Mr. Cascio:

          At your
     request, we are revising the language in the second to last page of our
     revised response letter, dated September 26, 2005 and filed on September
     27, 2005, to the comment letter (the “Comment Letter”) of the
     staff of the United States Securities and Exchange  Commission (the “Commission”)
     dated July 1, 2005 relating to the annual report on Form 20-F for the fiscal
     year ended December 31, 2004 filed by Canon, Inc.

          In connection with responding to the Comment Letter, Canon Inc. 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.

          *               *               *

          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 Mr. Katsuhito Yanagibashi of Canon in Tokyo
(Tel: +81-3-3758-2111;  Fax: +81-3-5482-5135),
Mr. Alan L. Forman of Ernst & Young ShinNihon in Tokyo (Tel: +81-3-3503-1106;
Fax: +81-3-3503-1277) or Mr. Ted
Paradise of Davis Polk & Wardwell in Tokyo (Tel: +81-3-5561-4430; Fax:
+81-3-5561-4425).

          Sincerely yours,

          /s/ Toshizo Tanaka

          [Toshizo Tanaka]

               [Senior Managing Director,

               Group Executive of
               Finance and

               Accounting Headquarters]

          cc:

          Ms. Kristin Lochhead

          Mr. Martin James

                  U.S. Securities
          and Exchange Commission

          Mr. Alan L. Forman

             Ernst & Young
          ShinNihon

          Ted Paradise, Esq.

                  Davis Polk & Wardwell, Tokyo Office