SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 4720                                                                                                   July 9, 2009   Mr. Steven J. Johnston Chief Financial Officer Cincinnati Financial Corporation 6200 S. Gilmore Road Fairfield, Ohio 45014-5141
Re:      Cincinnati Financial Corporation
Form 10-K for the Fiscal Year Ended December 31, 2008
Form 10-Q for the Quarter ended March 31, 2009
 File No. 0-04604

Dear Mr. Johnston:
We have reviewed your filing and have the following comments.  In our
comments, we ask you to provide us with  information to better understand your
disclosure.  Where a comment requests you to  revise disclosure, the information you
provide should show us what the revised disc losure will look like and identify the annual
or interim filing, as applicable, in which you intend to first incl ude it.  If you do not
believe that revised disclosure  is necessary, explain the reason in your response.  After
reviewing the information provided, we may raise additional comments and/or request
that you amend your filing.

 Please understand that the purpose of our re view 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 Fiscal Year Ended December 31, 2008

Quantitative and Qualitative Di sclosures About Market Risk

Application of Asset Impairment Policy, page 87
1. On page 88 you present a table that list s the number of secu rities and the gross
unrealized gain or loss for various classes of your investments. This table also
summarizes the length of time that securi ties in your portfolio  have been in a

Mr. Steven J. Johnston
Cincinnati Financial Corporation
July 9, 2009 Page 2
continuous unrealized gain or loss position. It appears that the totals of the unrealized gains and losses from this table agree with the gross unrealized gains and losses presented in Note 2 to yo ur financial statements on page 105.
However, the unrealized losses from this table do not appear to agree with the
table of loss duration in Note 2. As an  example, it appears from your table on
page 88 that the total gross unrealized losses on securities in a loss position from more than 12 months is $43 million (com prised of $25 million for those held 12
to 24 months and $18 million held more than 12 months) while the table on page
105 indicates that this am ount is $119 million. Please revise your disclosure to
clarify why these tables do not appear to agree.
 Financial Statements and Supplementary Data

Note 2. Investments, page 104
2. You provide disclosure with  the number of securities in your fixed maturity
investment portfolio that have been in  an unrealized loss pos ition for 12 months
or more. Please revise your disclosure to provide similar disclosure related to your
equity security investments for the periods provided as applicable.
3. Please revise your disclosure to explain why losses of $41 million on equity securities with a fair va lue of $79 million at December 31, 2008 that have been in
a continuous loss position for more than 12 months were not considered to be
other than temporary impairments a nd recognized as a loss under US GAAP.
Please tell us if any of these equi ty securities at December 31, 2008 were
subsequently sold and a realized loss was recognized. In addition, please explain
to us why none of the securities compri sing the $150 million in realized losses
during the first quarter of 2009 as di sclosed on page 32 of your March 31, 2009
Form 10-Q were not other-than-tempor arily impaired at December 31, 2008.

Form 10-Q for the quarter ended March 31, 2009

Managements Discussion and Analysis of Financial Conditio n and Results of

Operations
Results of Operations, page 23
4. You disclose loss and loss expense ratio s of 117.5% for workers’ compensation
policies, 96.0% for specialty packag e policies and 132.9% for homeowners
polices.  In the absence of disclosure to the contrary, we assume that these trends
will continue.  If this is not reasonably likely, please revise your disclosure to
explain.  Also, taking into considerat ion underwriting expenses the combined
ratios for these lines of business would be higher. Please explain to us why you
did not apparently record a premium defici ency related to these lines of business.
Please separately reference for us the authoritative literature you relied upon to
support your accounting. As required by para graph 60e of SFAS 60, please revise

Mr. Steven J. Johnston
Cincinnati Financial Corporation July 9, 2009 Page 3
 your accounting policy note to your financial statements to indicate whether or not you include anticipated investment income in your premium deficiency
computation.

*      *      *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that  keys your response to our
comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please furnish the letter to us via EDGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging 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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 Please contact Sasha Parikh, Staff Acc ountant, at (202) 551-3627 or Mark
Brunhofer, Senior Staff Account ant, at (202) 551-3638 if you have questions regarding
the comments.  In this regard, do not he sitate to contact me at (202) 551-3679.
 Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant