SecProbe.io

May 2, 2011
 Via E-Mail

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

Re: Kimberly-Clark Corporation
  Form 10-K for the Fiscal Year Ended December 31, 2010   Filed February 23, 2011
File No. 001-00225

Dear Mr. Falk:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
 Form 10-K filed February 23, 2011

 Item 11, Executive Compensation, incorporated by reference from Definitive Proxy Statement
Filed March 11, 2011
 Executive Compensation, page 41

 1. We note the statement on page 49 that th e compensation committee determined to
exercise its discretion to ad just the EPS performance measure from an actual of $4.45 to
the as-adjusted $4.68 to take into account a “[ o]ne-time charge related to adoption of
highly inflationary accounting in Venezu ela.”  You also state that the OPROS
performance measure was “adjusted for the same item described above in determining adjusted EPS.”  Please advise us in qu antified terms how the OPROS measure was

Thomas J. Falk
Kimberly-Clark Corporation May 2, 2011 Page 2

 adjusted and how these combined adjustments resulted in compensation set at “53 percent
of target,” as disclosed on page 51.  Also, pl ease revise future filings to provide further
disclosure of your policies and decisions regarding the adjust ment of performance
measures, clarify the extent to which the exerci se of such discretion a pplies to all or only
specified compensation subject to the relevant  performance goals, and clarify the factors
considered in decisions to increase or d ecrease compensation materially.  See Item
402(b)(2)(vi), (viii) and (ix) of Regulati on S-K.  Please provide draft disclosure.

2. The last two paragraphs on page 55 identify th ree types of perquisites provided to your
named executive officers.  It is unclear w hy your summary compensation table does not
quantify and describe each perquisite or othe r item pursuant to Instructions 3 and 4 of
Item 402(c)(2)(9) of Regulation S-K.  We note in this regard that the table reports all
other compensation for Messrs. Falk and Ab ernathy in excess of $306 thousand and $430
thousand, respectively.  Please provide draft disclosure.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Edwin S. Ki m at (202) 551-3297 or James Lopez, Branch Chief, at
(202) 551-3536 with any questions.

Sincerely,
         / s /  J a m e s  L o p e z  ( f o r )           John Reynolds
Assistant Director