SecProbe.io

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      May 10, 2005

By U.S. mail and facsimile to (414) 524-2077

Stephen A. Roell, CFO
Johnson Controls, Inc.
5757 N. Green Bay Avenue
Milwaukee, WI 53201

      Re:	Johnson Controls, Inc.
      Form 10-K for the year ended September 30, 2004
      File No. 1-5097

Dear Mr. Roell:

      We have reviewed your response letter dated April 20, 2005
and
have the following additional comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable.
In
some of our comments, we may ask you to provide us with
supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

Prior Comment 1
1.	In the amended 10-K, please clarify the "Pre-Production
Costs"
accounting policy disclosure on page 33 of your Annual Report.
Identify the account(s) that are impacted when you determine that
"reimbursement from the customer is contractually guaranteed".
Based
on our discussions and the disclosure in Note 15, it appears that
you
increase cash and decrease R&D expense. If another asset account
is
impacted then please identify the account, quantify the account
amount at each Balance Sheet date, and disclose the method and
time
period used to relieve the asset.

Prior Comment 3
2.	It appears that the five business units we previously
identified
are operating segments as contemplated by paragraph 10 of SFAS
131.
In this regard, we note that discrete financial information about
these five units is contained in management reports that are
regularly reviewed by both the CODM and the Board of Directors.
Paragraph 12 of SFAS 131 describes the CODM as a function that
involves both an assessment of operating performance and an
allocation of corporate resources. This appears analogous to an
isolation of positive and negative performance trends and
development
of improvement actions. Further, it appears that the management
reports contain data that is integral to the discussion of
resource
allocations that the CODM regularly has with the other executives.
Consequently, absent an ability to aggregate, it appears that the
segment data contained in your September 30, 2004 10-K does not
fully
comply with SFAS 131. Please amend the 10-K to provide the
disclosures outlined in paragraph 25 of SFAS 131 for each of the
reportable segments.

*    *    *    *

      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 responses to our comments and provides any
requested supplemental information.  Detailed response letters
greatly facilitate our review.  Please file your response letter
on
EDGAR as a correspondence file.  We may raise additional comments
after we review your responses.

      You may contact Jenn Li at (202) 942-1956, Al Pavot at (202)
942-1764 or me at (202) 942-1798 if you have questions regarding
these comments.

							Sincerely,

							Nili Shah
							Branch Chief
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Mr. Stephen A. Roell
May 10, 2005
Page 2 of 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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