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    Ms. Nili Shah

    Branch Chief

    Securities and Exchange Commission

    Washington, D.C. 20549-0510

    June 13, 2005

    Re:

    Johnson Controls, Inc.

    Comment letter dated May 10, 2005

    Commission File No. 1-5097

Dear Ms. Shah:

In response to the comment letter dated May 10, 2005 relating to Form 10-K for the year ended
September 30, 2004, the following is our response to comment (2). Based on discussions with the
Commission, we understand and agree with comment (1) and will make the suggested disclosures.

2. The Commission’s comment was as follows:

    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.

The Company maintains that it has historically appropriately defined and disclosed its operating
segments in accordance with the provisions of SFAS 131. In our previous responses filed with the
Commission, as well as during our discussion with the Staff on June 6, 2005, the Company outlined
its application of the criteria and guidelines of SFAS 131, specifically paragraphs 10-15 for
defining an operating segment. Items highlighted included:

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June 13, 2005

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    •

    The resource allocation process employed by the Chief Operating Decision Maker (CODM)
and his limited dependence on detailed Company financial reporting,

    •

    The use of an incentive compensation structure based on global performance for the
segment leadership and several layers of their management team,

    •

    The global and interdependent nature of our customer contracts, including the fact that
this results in geographic disclosures being less meaningful to users of our financial
statements,

    •

    The commonality of our customers, and

    •

    The technology and investment interdependencies across our product lines.

Additionally, the Company’s CODM maintains a regular dialogue with Mr. Keith Wandell, Executive
Vice President responsible for our Automotive segment and Mr. John Kennedy, Executive Vice
President responsible for our Controls segment. It is through these two executives that our CODM
makes resource allocation decisions and in so doing he relies on them for specific analysis and
underlying root cause issues that help him understand performance trends and more importantly
improvement actions at the global segment level.

Collectively, the above items, among others as previously discussed with the Staff, support our
interpretation of SFAS 131, paragraph 10b and the Company’s definition of its operating segments.
Nonetheless, we understand that there are subjective elements to this analysis. We acknowledge that
after our discussion with the Staff on June 6, 2005, the Company and the Commission differ
regarding these subjective and interpretive elements, and how the Company’s management practices
noted above apply to the criteria set forth in SFAS 131, paragraphs 10-15.

As a result of our discussions with the Staff, we understand the Commission’s point of view,
however, if the Commission’s interpretation of paragraph 10 of SFAS 131 was applied, the Company
believes that after applying the aggregation criteria set forth in paragraph 17 of SFAS 131, our
operating segments would result in the following three reportable segments:

    •

    Automotive Group

    •

    Controls Group

    •

    Battery Group

The Company’s response to the Commission will address why we believe that aggregation of the North
American and European regions of both our Seating & Interiors and Battery operations is appropriate
under SFAS 131. Specifically, paragraph 17 permits aggregation of operating segments if all of the
specified criteria are met. We provide the following analysis to illustrate our rationale in
aggregating the business units in question:

Criterion: Aggregation is consistent with the objective and basic principles of SFAS 131.

Discussion: We believe aggregation “by geographic region” is consistent with the
Statement’s objective and principles. SFAS 131, paragraph 4 states that the FASB chose
the “management approach” to determine what information should be reported on a segment basis to
achieve its objective and principles. Our “management approach” to the

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June 13, 2005

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allocation of resources on
a global basis and assessing performance is not based on geographic regions as evidenced above.
Also, as indicated in our letter to the Commission dated April 20, 2005, substantially all of our
customers are global manufacturers, with global product platforms and supplier requirements. This
fact requires our “management approach” be a global, customer-focused approach and not regionally
defined. For example, in most cases our manufacturing facility footprint is driven by our
customers’ requirements. As a result, we believe that disaggregating the North American and
European regions for both our Seating & Interiors and Battery operations would not significantly
enhance a user’s understanding of the Company, its financial results or future prospects,
consistent with the objective and basic principles of SFAS 131.

Criterion: The segments have similar economic characteristics.

Discussion: We believe that for both the Seating & Interiors and Battery operations, their
respective North American and European activities share similar economic characteristics. Our
long-standing management philosophy, communicated consistently both internally and externally, is
that as a company, we run our businesses according to the same principles worldwide. For example,
for our Seating & Interiors operations, we are a market leader in providing automotive seating,
overhead systems, cockpits systems, floor consoles, door systems and other interior systems. Our
market position and product portfolio is similar in both North America and Europe. To the extent
differences exist, we invest in a consistent manner to ensure we have the same world-class
capabilities across all regions. Again, because of the global nature of our customers, this
consistent approach is required.

When evaluating the
similarity of economic characteristics of operating segments, one
factor to be considered would
be the similarity of average gross margins on a long term basis. Although gross margins may vary
in any given year within a region due to a number of factors unique to the automotive industry, we
believe the average long term gross margins within our Automotive Seating & Interiors and Battery
businesses demonstrate the similarity of economic characteristics. The Company has
analyzed its historic and projected annual gross margins for the
Seating & Interiors and Battery businesses in North America and
Europe, and believe that the long term average gross margins for the
businesses reflect similar economic characteristics given appropriate
consideration to factors unique to the automotive industry.

In addition to exhibiting similar long term financial performance, the global nature of our
customers and the related global contracts also result in similar competitive and operating risks
across the Company’s geographical regions for the Seating & Interiors and Battery businesses. Our
key competitors are competitors on a global basis.

Similarly, from an operational perspective, we deploy best business practices, lean manufacturing,
Six Sigma, and other management practices on a consistent basis across regions. For example, we
have global operational benchmarks that both a seating plant in North America and one in Europe are
measured against. The benchmarks include sales
growth, gross margin, return on assets, days sales in accounts receivable, and inventory turnover.
Operations in both regions are managed to the same profitability, productivity and capital
efficiency standards.

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June 13, 2005

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In addition, externally reporting the performance of our North American and European activities
could, in fact, be misinterpreted by users of the Company’s financial statements because
investments are consistently leveraged across multiple geographies. For example, certain platforms
are developed and engineered in one region, but are manufactured and sold in another. To support
these platforms, the Company incurs significant engineering design and development costs in one
region, all of which are expensed as incurred as required by generally accepted accounting
principles, but produces and sells the product in another region.

Consistent with the requirements of SFAS 131, and absent the variation due to timing of
investments, program launches and footprint changes, we believe that after giving appropriate
weighting to the various economic characteristics for the respective activities in each geographic
region, they are so similar that they will have essentially the same future prospects.

Criterion: The nature of the products and services is similar.

Discussion: The nature of the products we sell are identical between geographical regions
for both Seating & Interiors and Battery operations. There is no difference between our vehicle
interiors or battery products manufactured in Europe compared to products produced in North
America. In both our Seating & Interior and our Battery business, engineering, design and
development is global. For example, in our Battery business we expect nickel metal hydride and
lithium-ion to represent significant growth opportunities for the Company as the market for hybrid
vehicles matures. In order to take advantage of economies of scale the Company is developing its
global nickel metal hydride technologies in Europe and its global lithium-ion technologies in the
USA.

In our Seating & Interiors business the Company’s seating structures (seat tracks, recliners and
seat frames) technologies and manufacturing processes were developed in North America and are
currently being quoted to OEM customers throughout North America, Europe and Asia. Similarly, our
electronics business develops instrument cluster technology in our engineering facility in
Pointoise, France. A key success in the Company’s acquisition strategy has been its ability to
migrate technology acquired in regional acquisitions globally.

Lastly, providing further evidence to the similarity of our global products, our purchasing
organization is globally managed under responsibility of Mr. Michael Bartschat, Vice President
Global Purchasing. Beneath Mr. Bartschat we are organized globally by commodity with purchasing
executives having global procurement responsibility for major components comprised of steel,
chemical, plastics/resins and indirect materials.

Criterion: The nature of the production processes is similar.

Discussion: The respective production processes are identical in each geographic region
for both the Seating & Interiors and Battery operations. In Seating and Interiors, the basic
business model involves component manufacture, assembly and just-in-time supply of complete seating
systems and other interior systems. The business model is based on the

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June 13, 2005

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deployment of common
processes such as: sew cell configuration and fabric and leather cutting; weld technology and
standard metal stamping bed sizes; foam chemical composition and pour weights; and assembly line
configuration, manning and tool design. As stated previously, common principles regarding best
business practices, lean manufacturing, etc. also ensure the inherent similarities in processes.
Similarly, the basic processes of automotive battery production do not differ between geographic
regions. Commonality exists in all processes including lead alloys utilized, water bath formation,
and grid and plate manufacturing.

Criterion: The type or class of customer is similar.

Discussion: The respective customers are similar in each geographic region for both the
Seating & Interiors and Battery operations. As stated earlier, the majority of our customers are
global automotive manufacturers that require us to be in the region in which they operate.
Increasingly, our automotive customers are developing global platforms and mandating that their
suppliers be able to support their production facilities globally. In our previous submission we
outlined a few specific examples such as the Mercedes M Class and the Nissan X61B platforms. In
addition to the automotive manufacturers, we also have customers for batteries in the aftermarket.
There are no significant differences in these types of aftermarket customers between geographic
regions. In both North America and Europe, we sell through the OES, independent aftermarket and
retail channels.

Criterion: The methods used to distribute products or provide services are similar.

Discussion: The product distribution methods are similar in each geographic region for
both the Seating & Interiors and Battery operations. No significant differences in distribution
methods or channels exist with respect to geographic region.

Criterion: If applicable, the nature of the regulatory environment is similar (for
example, banking, insurance or public utilities).

Discussion: Not applicable.

In summary, the Company believes that our historic interpretation and application of SFAS 131 has
not been unreasonable and that it has appropriately defined and disclosed its operating segments.
The Company acknowledges that the Commission’s interpretation of paragraphs 10-15, absent
aggregation, may yield additional operating segments. However, we believe that after the
aggregation criteria of paragraph 17 are applied, the result is three reportable segments. Based on
our various discussions with the Staff, and in order to arrive at a mutually acceptable resolution
of this matter that would provide additional
meaningful disclosure to the readers of the Company’s financial statements, we have re-evaluated
paragraphs 10-15 and paragraph 17 of SFAS 131, including the fact that our Battery business is a
growing part of our Automotive business due to recent acquisitions and organic growth, and we
propose disclosing three reportable segments: Automotive, Controls and Battery. In addition, we
will expand our geographical disclosures of the three proposed operating segments within
Management’s Discussion & Analysis, as appropriate.

Ms. Nili Shah

June 13, 2005

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Furthermore, based upon the reasonableness of the Company’s historical interpretation of SFAS 131
and the subjective application and interpretive nature of certain paragraphs of SFAS 131, we
propose to prospectively adopt the Commission’s interpretation of paragraphs 10-15 of SFAS 131 with
aggregation to three reportable segments and clarify our accounting for pre-production costs as
addressed in the Commission’s comment (1) beginning with the fiscal quarter ending June 30, 2005.
We are providing under separate cover additional information for the Commission illustrating our
March 31, 2005 segment detail as revised for our proposed presentation as well as our re