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August 16, 2005

Mr. Will Choi

Accounting Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

  Re:

  The Coca-Cola Company

  Form 10-K for the fiscal year ended December 31,
  2004

  Filed March 4, 2005

Dear Mr. Choi:

Thank you for your letter dated August 2, 2005, regarding our
response to the Staff’s comment letter dated April 27, 2005.

The Coca-Cola Company’s (“KO” or the “Company”) response to the Staff’s
comment is set forth below.

To facilitate the Staff’s review, we have included in this letter the
caption and numbered comment from the Staff’s letter and have provided KO’s
response immediately following each numbered comment.

Item 7.
Management’s Discussion and Analysis of Financial Condition and Results
of Operations, page 24

Application of Critical Accounting Policies, page 31

1.              We have reviewed
your response to prior comment 2 of our letter dated April 27, 2005.  Please help us understand your basis for
determining that your operations in Germany and the Nordic region should be
aggregated and deemed a single reporting unit for goodwill impairment testing
purposes.  In this regard, please discuss
the impact of economic situation in Germany as compared to that of the Nordic
region, including the impact of Germany’s participation in the euro, on your
operations.  See paragraph 30 of SFAS No. 142.  Please also clarify for us whether you would
have recognized goodwill impairment related to CCEAG if Germany were a single
reporting unit.

Reporting Unit

Paragraph 30 of Statement of Financial
Accounting Standards No. 142, “Goodwill and Other Intangible Assets” (SFAS
No. 142) contains the primary guidance related to determining reporting
units for purposes of the annual goodwill impairment tests.  Paragraph 30 of SFAS No. 142 reads as
follows:

30.                               A
reporting unit is an operating segment or one level below an operating segment
(referred to as a component). (17) A
component of an operating segment is a reporting unit if the component
constitutes a business(18) for which discrete financial
information is available and segment management(19)
regularly reviews the operating results of that component.  However, two or more components of an
operating segment shall be aggregated and deemed a single reporting unit if the
components have similar economic characteristics.(20) An
operating segment shall be deemed to be a reporting unit if all of its
components are similar, if none of its components is a reporting unit, or if it
comprises only a single component.  The
relevant provisions of Statement 131 and related interpretive literature shall
be used to determine the reporting units of an entity.

(17) For purposes of determining reporting units, an operating segment is
as defined in paragraph 10 of FASB Statement No. 131, Disclosures about
Segments of an Enterprise and Related Information.

(18) Emerging Issues Task Force Issue No. 98-3, “Determining Whether a
Nonmonetary Transaction Involves Receipt of Productive Assets or of a Business,”
includes guidance on determining whether an asset group constitutes a business.

(19) Segment management consists of one or more segment managers, as that
term is defined in paragraph 14 of Statement 131.

(20) Paragraph 17 of Statement 131 shall be considered in determining if
the components of an operating segment have similar economic characteristics.

In accordance with Paragraph
30 of SFAS No. 142, in order to determine our reporting units, the first
step we considered was our operating segments.
In 2004, the Company’s operating segments were as follows:

North America

Africa

Asia

Europe, Eurasia and Middle
East

Latin America

Corporate

Each of the Company’s
operating segments, with the exception of Corporate, has a segment manager
responsible for that operating segment who reports directly to the Chief
Executive Officer of the Company.

A reporting unit is defined
in SFAS No. 142 as an operating segment or one level below an operating segment
(referred to as a component).  In the
Company’s reporting hierarchy, a Division is one level below the operating
segment.  The Company’s grouping of
geographic businesses into Divisions reflects management’s judgments about

the optimal structure to
manage such businesses and report their financial results to their segment
management.  Segment management reviews
the financial results and manages the business at the Division level.   In
2004, our Germany and Nordic Division was part of our Europe, Eurasia and
Middle East operating segment, which also included the Central Europe and
Russia Division, the Eurasia and Middle East Division, the Italy and Alpine
Division, the Southeast Europe Division, the Iberian Division, and the Northwest
Europe Division.

Our Germany and Nordic Division
is a business as defined by Emerging Issues Task Force Issue No. 98-3. In
addition, the Germany and Nordic Division reports discrete financial
information which is regularly reviewed by segment management in the analysis
and assessment of the results of the Europe, Eurasia and Middle East operating
segment.  Division managers are held
accountable by the segment managers for their Division’s operational and
financial results.

Based on this analysis, the
Company concluded that the Germany and Nordic Division, which is one level
below our Europe, Eurasia and Middle East operating segment, met the definition
of a component of an operating segment under SFAS No. 142.  Because we concluded that the Germany and
Nordic Division was a component of an operating segment, we were not required under
SFAS No. 142 to assess the economic similarities between the
sub-components of the Division.

SFAS No. 142 requires
that two or more components, in our case Divisions, of an operating segment be
aggregated and deemed a single reporting unit if the components have similar
economic characteristics.  The Company
reviewed the criteria provided by paragraph 17 of Statement of Financial
Accounting Standards No. 131, “Disclosures about Segments of an Enterprise
and Related Information.”   Based on this
review, we determined that our Europe, Eurasia and Middle East Divisions did
not meet the similar economic characteristics criteria.  Accordingly, we have not aggregated any of
these Divisions in conducting our annual goodwill impairment tests.

Therefore, we concluded that
our Germany and Nordic Division was a component of our Europe, Eurasia and
Middle East operating segment and a reporting unit as defined in SFAS No. 142.

Treating Germany as if It Were
a Reporting Unit

If Germany was a reporting unit, the Company still would not have
recognized a goodwill impairment charge related to CCEAG during 2004 because
the fair value of the reporting unit would significantly exceed the carrying
value of the reporting unit.

If you have any questions or require additional information regarding
the matters addressed in this letter, please contact me at 404-676-3497 or via
fax at 404-515-2554.

Sincerely,

  /s/ Connie D. McDaniel

  c:

  E. Neville Isdell, Chairman, Board of
  Directors, and Chief Executive Officer

  Gary P. Fayard, Executive Vice President
  and Chief Financial Officer

  Peter V. Ueberroth, Chairman of the Audit
  Committee of the Board of Directors