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    Mr. John Hartz

Senior Assistant Chief Accountant

Securities and Exchange Commission

Washington, D.C. 20549-0510

    March 16, 2005

    Re:
    Johnson Controls, Inc.

Comment letter dated March 2, 2005

Commission File No. 1-5097

Dear Mr. Hartz:

In response to the comment letter dated March 2, 2005 relating to the review of our filings of the
Annual Report on Form 10-K for the fiscal year ended September 30, 2004, the Form 8-K filed on
October 12, 2004 and the Quarterly Report on Form 10-Q for the period ended December 31, 2004, the
following are our responses to comments (4), (6), (7), and (8). As recommended by your letter,
Johnson Controls, Inc.’s (“the Company” or “JCI”) future filings will address the matters noted in
comments (1), (2), (3), (5), (9), (10), (11), (12), and (13).

    4.
    The Company does not reverse amounts expensed in previous periods upon receipt of a
contractual guarantee for reimbursement from its customers in accordance with EITF 99-5,
“Accounting for Pre-Production Costs Related to Long-Term Supply Arrangements.”

    6.
    The Company’s Equity Swap Agreement (“Agreement”) has a stated expiration date of one
calendar year from the initial effective date. However, the Agreement provides for
transactions (“swap contracts”) to be executed under the Agreement indefinitely upon mutual
consent between JCI and Citibank. JCI intends to continually renew the swap contracts for
rolling periods of up to 12 months. JCI presently initiates new swap contracts every six
months. Therefore, the ultimate expiration date of the Agreement is not currently
determinable; however, the renewal features of the Agreement will be disclosed in future
annual filings and future interim filings as applicable.

    If the Company’s stock price increases, our only risk is the credit risk of Citibank. Under the
Agreement, Citibank has the obligation to pay us in cash for any increase in value of a contract
under the Agreement from the beginning to the end of the contract period. Such risk extends
during the course of each contract issued under the Agreement; the current swap contract is for
a period of six months. Citibank is rated Aa1 by Moody’s and AA by S&P, and thus, we believe
that this risk is immaterial, particularly in light of the short duration of the period of risk.
Conversely, if the Company’s stock price decreases, JCI has the same obligation to pay Citibank
in cash. As such, the Company records a

Mr. John Hartz

March 16, 2005

Page 2 of 4

    receivable/payable at each period end related to the asset/obligation related to the underlying
swap contract, with a corresponding decrease/increase to compensation expense.

    Certain of our equity compensation liabilities increase as our stock price increases and
decrease as our stock price decreases. The value of our Swap Agreement moves in the opposite
direction of those liabilities. As a result, we now have limited income statement volatility
risk with respect to an increase/decrease in our stock price. The Company has hedged
approximately 80-100% of its equity compensation liabilities. The Company pays floating amounts
to Citibank under the Agreement, which effectively represent financing costs and are recognized
over the term of the Agreement.

    In future filings, our disclosure language will be expanded to include this discussion.

    7.
    The Company reported a valuation allowance of approximately $572 million against net
operating losses, tax carryforwards and net deferred tax assets in certain foreign
jurisdictions as of September 30, 2004. The valuation allowance relates to legal entities in
certain jurisdictions in which the Company has accumulated losses in recent years, does not
have a history of sustained profitability, does not have the expectation of generating certain
classes of future income needed to realize the respective tax assets and/or has limited
carryforward periods.

    We are sending under separate cover the supplemental information you requested to clarify the
basis for recording this valuation allowance for entities in our material jurisdictions ($500
million of the $572 million valuation allowance) in accordance with paragraphs 20-21 of SFAS
109. We are providing these materials to the Staff on a confidential basis pursuant to Rule
12b-4 under the Securities Exchange Act of 1934, as amended. In accordance with such rule, we
hereby request that the Staff return the materials referred to above promptly following the
Staff’s review of such materials. By separate letter, we have requested confidential treatment
of such materials pursuant to the provisions of 17 C.F.R. 200.83.

    In accordance with paragraph 17 of FAS 109, we believe that at September 30, 2004, it is more
likely than not that such tax assets will not be realized in those jurisdictions after due
consideration is given to all positive and negative evidence. As recommended by your letter, in
future filings our disclosure language will be expanded to include those jurisdictions with
material net operating losses, tax carryforwards and net deferred tax assets, including related
impairment considerations.

    8.
    The Company believes that its automotive and controls businesses represent its two operating
segments, as defined by paragraph 10 of SFAS No. 131, because (i) they earn revenue and incur
expenses, (ii) these segment operating results are regularly reviewed by the Company’s chief
operating decision maker (“CODM”) to assess performance and to decide how to allocate
resources, and (iii) discrete financial information on their activities is available.

Mr. John Hartz

March 16, 2005

Page 3 of 4

    The Company’s CODM is its Chairman and Chief Executive Officer. To assess performance and
allocate resources, the CODM regularly reviews information, including the Company’s monthly
internal consolidated financial statements and related budget information, which presents data
on a combined basis about the operating segments. Similarly, financial information presented to
and used by the Company’s Board of Directors each month to assess the financial performance of
the operating segments is combined at this level.

    The CODM also reviews discrete information about the activities of the segment in which data is
further sub-divided by region, line of business, etc. However, he relies on consolidated
information at the segment level to make strategic decisions because of the interrelationships
between the activities. In other words, the CODM does not make strategic decisions about each
activity independently of the others because of the interrelated nature of the activities. The
CODM evaluates data at the operating segment level to allocate resources and assess performance.

    The Company has historically followed a policy of announcing all appointments of corporate
officer level positions. The Company believes that the recent news releases announcing these
officer level positions identified by the Commission is not inconsistent with the principles of
SFAS 131. Paragraph 14 states that “an operating segment has a segment manager who is directly
accountable to and maintains regular contact with the chief operating decision maker.” The
Company’s two operating segments are managed by Keith E. Wandell (Automotive Group) and John P.
Kennedy (Controls Group). Each of these executives is directly accountable for all aspects and
regions of their respective businesses and maintains regular contact with the Company’s CODM.

    In managing the global business operations of their respective operating segments, Mr. Wandell
and Mr. Kennedy each have a full time dedicated management team providing day to day support. The
segment management team includes financial, legal, human resources, strategy planning, and
communications personnel. In addition, Mr. Wandell, Mr. Kennedy and their management teams
incentive compensation arrangements are directly related to the stand alone operating results of
their segment.

    The Company believes that, while there have been announcements concerning vice presidents and/or
general managers of certain geographic areas, their appointments are not relevant in determining
operating segments of the Company based on how the CODM allocates resources and assesses
performance as noted above.

    In response to your request, we are sending under separate cover as supplemental information a
sample of the monthly reports used by the CODM. We are providing these materials to the Staff
on a confidential basis pursuant to Rule 12b-4 under the Securities Exchange Act of 1934, as
amended. In accordance with such rule, we hereby request that the Staff return the materials
referred to above promptly following the Staff’s review of such materials. By separate letter,
we have requested confidential treatment of such materials pursuant to the provisions of 17
C.F.R. 200.83.

Mr. John Hartz

March 16, 2005

Page 4 of 4

The supplemental information referenced above will be sent to the Commission for receipt no later
than Thursday, March 17, 2005. If there are any further comments or questions, please do not
hesitate to contact me at (414) 524-1200.

Very truly yours,

JOHNSON CONTROLS, INC.

/s/ Stephen A. Roell

Stephen A. Roell

Executive Vice President and

Chief Financial Officer