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CORRESP
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corresp

Ms. Nili Shah

Branch Chief

Securities and Exchange Commission

Washington, D.C. 20549-0510

September 14, 2005

    Re:

    Johnson Controls, Inc.

    Comment letter dated August 30, 2005

    Commission File No. 1-5097

Dear Ms. Shah:

In response to the comment letter dated August 30, 2005 relating to our Form 10-Q for the periods
ended March 31, 2005 and June 30, 2005, the following is Johnson Controls, Inc.’s (the “Company”)
response to the Staff’s comments.

Prior Comments 1, 2, and 3: The Commission’s comment was as follows:

We have read your response to prior comments 1, 2, and 3 in our letter dated August 5,
2005. In future filings, please provide this clarifying information in your
management’s discussion and analysis. In this regard, please disclose that:

    •

    The voluntary tax election resulted in a capital loss of $539 million.

    •

    You utilized $187 million of the capital loss during the six months ended
March 31, 2005, resulting in a decrease in your provision for income taxes of
$80.5 million as compared to the prior period.

    •

    You have fully provided for the remaining capital loss of $352 million.

    •

    The reasons for your full valuation allowance, as identified in the four
bullet points in your response to prior comment 2.

As recommended in your letter, the Company will include the above clarifying information in
management’s discussion and analysis (“MD&A”) in its Form 10-K for the year ended September 30,
2005. It should be noted that the tax benefit recorded by the Company for the utilization of the
$187 million capital loss was $69 million and the remaining $11.5 million tax benefit related to a
“check-the-box” election in the Company’s first quarter ended December 31, 2004.

4. The Commission’s comment was as follows:

You state that you have been increasingly offering discounts instead of warranties
resulting in a decline in the overall warranty liability. In future filings, if
material, please quantify the impact of this trend on your operating results and
explain the key business, competitive, political, and/or economic factors for offering
these discounts in your management’s discussion and analysis.

Ms. Nili Shah

September 14, 2005

Page 2 of 2

As recommended in your letter, the Company will include the above information, if material, in
future filings.

4. The Commission’s comment was as follows:

You state that the decrease in the operating income of Seating & Interiors – North
America was primarily due to continued price reductions and material cost pressures and
the deconsolidation of a joint venture, partially offset by a favorable mix compared to
industry production, operational cost savings and lower engineering expenses. Please
quantify the impact of the deconsolidation of the joint venture on the segment’s sales
and operating profit. Please also explain to us the basis for consolidation prior to
April 1, 2005 and deconsolidation subsequent to that date in accordance with generally
accepted accounting principles. As part of your response, please clarify the rights
and obligations associated with your equity ownership, as well as any other interests
you hold in this joint venture. Please also clarify how operating control of the joint
venture is determined and the circumstances resulting in the change in operating
control, based on your statement in your Form 8-K filed July 21, 2005, “On April 1,
2005, a seating and interiors joint venture was deconsolidated due to a change in
operating control.”

[Redacted Information]

If there
are any further comments or questions, please do not hesitate to contact me at (414) 524-3422.

Very truly yours,

JOHNSON CONTROLS, INC.

/s/ Jeffrey Augustin, Vice President and Corporate Controller, for R. Bruce McDonald

R. Bruce McDonald

Vice President and

Chief Financial Officer