SecProbe.io

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                  November 3, 2005

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

R. Bruce McDonald
Vice President and Chief Financial Officer
Johnson Controls, Inc.
5757 N. Green Bay Avenue
Milwaukee, WI 53201

      Re:	Johnson Controls, Inc.
      Form 10-Q for the period ended June 30, 2005
      Filed August 9, 2005
      File No. 1-5097

Dear Mr. McDonald:

      We have reviewed your response letter dated October 17, 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.

Form 10-Q for the period ended June 30, 2005

Management`s Discussion and Analysis, page 20

Operating Income, page 22

1.	We have read your response to prior comment 1 in our letter
dated September 28, 2005.  It remains not evident to us that you
controlled Joint Venture 1 (JV1), in the manner contemplated by
SFAS
94, prior to the deconsolidation.  If you conclude that your prior
filings should not be relied upon, please be advised that you are
required to disclose the information listed under Item 4.02(a) of
Form 8-K within four days of your conclusion.

Please correct your accounting for JV1 in accordance with APB 18
in
your Form 10-K for the fiscal year ended September 30, 2005.  In
your
Form 10-K, address the following:
* An explanatory paragraph in the audit opinion.
* Full compliance with APB 20 paragraph 37.

* Fully update all affected portions of the document, including
MD&A,
selected financial data, and quarterly financial data.
* Updated Item 9A. disclosures should include the following:
o A discussion of the correction and the facts and circumstances
surrounding it.
o How the correction impacted the CEO and CFO`s original
conclusions
regarding the effectiveness of their disclosure controls and
procedures.
o Changes to internal controls over financial reporting
o Anticipated changes to disclosure controls and procedures and/or
internal controls over financial reporting to prevent
misstatements
of a similar nature.
Refer to Items 307 and 308(c) of Regulation S-K.

      In addition, please amend the following:
* Your Forms 10-Q for the quarters ended December 31, 2004 and
March
31, 2005.
* Your Form 10-Q for the quarter ended June 30, 2005, due to the
impact on prior quarter comparative financial information.

2.	Please provide a materiality analysis by segment by quarter
for
the past three years for Joint Venture 2 (JV2).  Should you
determine
JV2 to be material, please provide an analysis that demonstrates
in
further detail how you controlled the joint venture given the
guidance in SFAS 94, and tell us why you believe that equity
method
accounting under APB 18 was not appropriate.  In this regard,
* Please tell us who the other investor is and whether they are
related to the primary customer supplied by the joint venture.
* Please provide us with a copy of the joint venture agreement and
any other relevant contracts.
* Describe the recent financing commitments made by you to the
joint
venture.
* Identify the material rights and obligations, as stated in the
joint venture agreement, possessed by each of the investors and
explain how such rights are consistent with your determination
that
you had control as contemplated by SFAS 94.  In addition, address
the
following:
o Identify the governing body, the number of members on this body,
and the rights of each investor to appoint and remove these
members.
o Describe the ability of each investor to participate in
operating
and capital decisions.  Tell us the rights held by the other
investor
in the event of a dispute or deadlock.
o Tell us who, if anyone, has the unilateral authority to
establish
business relationships, employee compensation, and financial
forecasts/budgets.

o Tell us whether you have any puts, calls, or rights of first
refusal over the interests of the other investor.
In your response, please cite the specific paragraphs in the joint
venture agreement on which you rely.

*    *    *    *

      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 Do at (202) 551-3743, Al Pavot at (202)
551-3738 or me at (202) 551-3255 if you have questions regarding
these comments.

						Sincerely,

						Nili Shah
	Branch Chief
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Mr. R. Bruce McDonald
Johnson Controls, Inc.
November 3, 2005
Page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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