SecProbe.io

Room 4561
      July 20, 2006

Mr. Thomas J. Falk
Chief Executive Officer
Kimberly-Clark Corporation
P.O. Box 619100
Dallas, Texas  75261-9100

Re: Kimberly-Clark Corporation
 Form 10-K for Fiscal Ye ar Ended December 31, 2005
 Filed February 23, 2006
 Form 10-Q for the period ended Ma rch 31, 2006 filed May 5, 2006
 Form 8-K filed during Fiscal 2006
 File No. 1-225

Dear Mr. Falk:

We have reviewed your response letter dated May 22, 2006 and have the
following comments.  Where indicated, we think you should revise your document in
response to these comments.  If you disagree, we will consider your explanation as to
why our comment is inapplicable or a revisi on is unnecessary.  Please be as detailed as
necessary in your explanati on.  In our comment, we ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Thomas J. Falk
Kimberly Clark Corp.
July 20, 2006 Page 2

Form 10-Q for the Quarterly Period Ended March 31, 2006

Financial Statements

Notes to Consolidated Financial Statements

Note 3. Competitive Improvements Initiative, page 7
1. We note your response to prior comment number 1 from our letter dated May 10,
2006.  To help us understand your basis for concluding that your cost improvement initiative represents a si ngle plan for financial reporting and
disclosure purposes, provide us with the following:
• Tell us whether the initiative, as auth orized by the your Board of Directors
in July 2005, specifically identified all actions to be taken to complete the
initiative, the activities th at will not be continue d, including the method of
disposition and location of those ac tivities, and the expected date of
completion;
• Tell us whether any additional approval s or authorizations from the Board
of Directors, beyond the July 2005 au thorization, will be  necessary to
complete the initiative; and,
• In view of the length of  the initiative, explain your basis for concluding
that significant changes to th e initiative are not likely.
2. Disclosure included in your Form 8-K dated January 23, 2006 indicates that, on
January 18, 2006, the corporation authori zed two subsequent phase projects
pursuant to the competitive improvement in itiative.  Explain to us how the actions
under the two subsequent phase project re late to the initia tive as originally
authorized in July 2005.  Additionally, explain specifically what actions or
activities were authorized on January 18, 2006.  Also, given that the initiative was
authorized in July 2005, explain why the January 2006 authorizations were
necessary.  Finally, explain how  this apparent need for additional authorizations is
consistent with your conclusion that the initiative represented a single plan.

Form 8-K filed April 24, 2006
3. Your response to prior comment num ber 4 from our letter dated May 10, 2006
describes various reasons why you believe charges incurred in connection with
your competitive improvements to be unusual.  However, Item 10(e)(ii)(B) of regulation S-K indicates that  it is not appropriate to describe an item as unusual

Mr. Thomas J. Falk
Kimberly Clark Corp.
July 20, 2006 Page 3
when the nature of the item is such that it  is reasonably likely to recur within two
years.  While the prohibition identified in 10(e)(ii)(B) of Regulation S-K is not
applicable to furnished information, the guidance with respect to what constitutes an “unusual” item for purposes of non-GAAP presentations appears applicable to
both furnished and filed information.

Based on the description of your initiative contained in various of your filings, it
appears that charges related to asset imp airments, asset write-offs and workforce
reductions will recur in numerous future periods.  In view of this, and given the
guidance of Item 10(e)(ii)(B) of Regulation S-K, it does not appear appropriate to
describe charges related to your initiative as unusual.
4. Your response to prior comment num ber 5 from our letter dated May 10, 2006
suggests that you do not believe  that the guidance in the responses to Questions 8
and 9 of the Staff’s Frequently Aske d Questions Regarding the Use of Non-
GAAP Financial Measures is applicable to  information that is furnished and not
filed.  However, the final sentences under the responses to both Questions 8 and 9
clearly indicate that the guidance ma y apply to furnished information.

As your non-GAAP measures exclude items that  appear to be recurring in nature,
you must meet the burd en of demonstrating the usefulness of the measures.  Such
measures more likely would be permi ssible if you reasonably believe it is
probable that the financial impact of the item will disappear or become immaterial
within a near-term finite period.  In add ition, inclusion of such measures may be
misleading absent the following disclosure:

• The manner in which management uses the non-GAAP measure to
conduct or evaluate its business;

• The economic substance behind management's decision to use such a
measure;

• the material limitations associated with use of the non-GAAP financial
measure as compared to the use of the most directly comparable GAAP financial measure;

• the manner in which management compensates for these limitations when using the non-GAAP financial measure; and

• the substantive reasons why management believes the non-GAAP
financial measure provides useful information to investors.

Mr. Thomas J. Falk
Kimberly Clark Corp.
July 20, 2006 Page 4
 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  Please submit all
correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T.  You may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cove r letter with any amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing any amendment and your responses to our comments.

 You may contact Marc Thomas, Senior Staff Accountant at (202) 551-3452 or me
at (202) 551-3489 if you have questions regarding these comments.

Sincerely,

Brad Skinner
       A c c o u n t i n g  B r a n c h  C h i e f