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Response Letter to the SEC

 SIDLEY AUSTIN LLP

 ONE SOUTH
DEARBORN

 CHICAGO, IL 60603

 (312) 853 7000

 (312) 853 7036 FAX

 BEIJING

 BRUSSELS

 CHICAGO

 DALLAS

 FRANKFURT

 GENEVA

 HONG
KONG

 LONDON

 LOS ANGELES

 NEW YORK

 SAN FRANCISCO

 SHANGHAI

 SINGAPORE

 SYDNEY

 TOKYO

 WASHINGTON, D.C.

 wcarlson@sidley.com

 (312)853-7734

FOUNDED 1866

 June 14, 2007

 Mr. Mark Kronforst

 Accounting Branch Chief

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street, NE, Room 4561

 Washington, D.C. 20549

Re:
Response of Kimberly-Clark Corporation to the

Staff’s Comment Letter Dated May 31, 2007

File No. 1-225

 Dear Mr. Kronforst:

 On behalf of our client, Kimberly-Clark Corporation, we are submitting this letter, together with the enclosed document entitled “Response of
Kimberly-Clark Corporation to the Staff’s Comment Letter Dated May 31, 2007,” in response to the comments contained in the letter dated May 31, 2007 from the Staff of the Securities and Exchange Commission (the
“Commission”) to the Company.

 On behalf of the Company, we also acknowledge (as you requested in your letter of May 31,
2007) that:

(1)
the Company is responsible for the adequacy and accuracy of the disclosure in the filings;

(2)
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and

(3)
the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Sidley Austin LLP is a limited liability partnership
practicing in affiliation with other Sidley Austin partnerships

 Mr. Mark Kronforst

 Securities
and Exchange Commission

 June 14, 2007

 Page 2

 If you have any questions concerning this letter or the Response, please contact the undersigned at (312) 853-7734.

Very truly yours,

/s/ Walter C. Carlson

 WCC:dsd

 Enclosure

 RESPONSE OF KIMBERLY-CLARK CORPORATION TO THE STAFF’S COMMENT LETTER DATED MAY 31, 2007

This document responds to the Staff’s letter dated May 31, 2007 (the “Staff’s Comment Letter”) to Kimberly-Clark Corporation in which
the Staff commented on Kimberly-Clark Corporation’s Form 10-K for the fiscal year ended December 31, 2006, filed February 22, 2007 (the “2006 Form 10-K”) and Form 10-Q for the quarter ended March 31,
2007, filed May 9, 2007 (the “2007 Q1 Form 10-Q”). References to “We”, “Us”, “Our”, “K-C” or the “Company” in this letter or the attachments hereto mean Kimberly-Clark
Corporation.

 For convenience, the Staff’s comments are retyped below.

 Staff Comments and Company Responses

 Form 10-K for the Fiscal Year Ended December 31, 2006

 Item 8. Financial Statements and Supplementary Data

 Consolidated Financial Statements

 Consolidated Income Statement, page 37

 Staff Comment No. 1:

 Please explain to us how your
presentation of essentially all of your operating expenses as marketing, research and general expenses complies with Item 5-03 of Regulation S-X.

 Company’s Response:

 We believe the presentation of our Consolidated Income Statement complies with the requirements of Rule 5-03
of Regulation S-X (“Rule 5-03”). The “Marketing, research and general expenses” caption on our Consolidated Income Statement is analogous to Item 4 in Rule 5-03 titled “Selling, general and administrative
expenses”. Our caption “Cost of products sold” is inclusive of all costs of tangible goods sold as described in Item 2 of Rule 5-03. We do not have any “other operating costs and expenses” as described in Item 3 of
Rule 5-03.

 Our Consolidated Income Statement presentation is similar to that of other consumer packaged goods companies.

 In note 18, Supplemental Data, to the financial statements contained in our 2006 Form 10-K, we separately disclose the amounts of advertising expense and
research expense included in “Marketing, research and general expenses.”

 Based on the above and our ongoing review of the expenses included in
our Marketing, research and general expenses caption, we believe that we do not need to display additional captions on the face of our Consolidated Income Statement related to these expenses.

 Consolidated Statement of Stockholders’ Equity, page 39

 Staff Comment No. 2:

 We note that your adjustment to initially apply SFAS 158 is presented as part of comprehensive income for
the year ended December 31, 2006. Please tell us how this complies with paragraph A7 of the standard.

 1

 Company Response:

 When we adopted SFAS 158, we relied on the definition of comprehensive income contained in paragraphs 8 and 9 of SFAS 130, i.e., comprehensive income is defined as “….the change in equity [net assets] of a
business enterprise during the period from transactions and all other events and circumstances from nonowner sources.” Because the SFAS 158 transition adjustment arises from a nonowner source, it is by definition, a component of
comprehensive income. We did not rely on paragraph A7 because it includes the statement that “The table (below) is not intended to illustrate the disclosure requirements of this Statement”. Only recently, have we been made aware that the
FASB staff’s interpretation of paragraph A7 indicates the adjustment should not be included in comprehensive income.

 We evaluated our presentation in
accordance with Staff Accounting Bulletins No. 99, Materiality (SAB Topic 1.M.) and No. 108, Considering the Effects of Prior Year Misstatements when Quantifying Misstatements in Current Year Financial Statements (SAB
Topic 1.N.) and concluded that this presentation does not quantitatively or qualitatively materially misstate our Consolidated Financial Statements given the transparency in our Consolidated Statement of Stockholders’ Equity of the
components of Other Comprehensive Income and the SFAS 158 transition amount. We believe that our conclusion is supported by the guidance in paragraph 13 of SFAS 130 that states, in part, that “Information about the components of
comprehensive income often may be more important than the total amount of comprehensive income.”

 Earlier today, we filed a Form 8-K to furnish a
recast of Item 8. Financial Statements and Supplementary Data from our 2006 Form 10-K. That recast of Item 8 relates to a change in our reportable segments as discussed in MD&A in our first quarter 2007 Form 10-Q. We recast
the presentation of our reportable segments for all periods reported in our Annual Report on Form 10-K for the year ended December 31, 2006 to conform to the new reporting structure.

 In the above mentioned Form 8-K, we also adjusted the 2006 Consolidated Statement of Stockholders’ Equity to exclude the SFAS 158 transition amount from
comprehensive income to conform to the presentation outlined in paragraph A7. In addition, we modified Note 9, Stockholders’ Equity, so that the display of Accumulated Other Comprehensive Income clarifies the effect of the transition
adjustment. We have included the applicable table from the original version of the Note (as it appeared on page 61) as Attachment A and the modified version of the table as Attachment B. We also intend to disclose the adjustment to
our presentation of the 2006 Consolidated Statement of Stockholders’ Equity in a note in our interim financial statements for the period ending June 30, 2007.

 2

 Form 10-Q for the Period Ended March 31, 2007

 Item 1. Financial Statements

 Notes to the Consolidated Financial Statements

 Note 2. Accounting for Uncertainty in Income Taxes, pages 5-6

 Staff Comment No. 3:

 Tell us what consideration you have given to disclosing the total amounts of interest and penalties recognized
in the statement of operations in the quarter ended March 31, 2007 pursuant to paragraph 21c of FIN 48.

 Company Response:

 In developing our disclosure with respect to paragraph 21c. of FIN 48, we relied on the guidance developed at the September 26, 2006
meeting between the AICPA SEC Regulations Committee and the SEC staff. We understand that the SEC staff indicated that it will not require the disclosures under paragraphs 20 and 21 of FIN 48 be included in interim financial
statements after the date of adoption. However, interim financial statements should present those disclosures as of the date of adoption in the first interim period that includes the date of adoption. The date-of-adoption disclosures should be
included in each set of interim financial statements during the year of adoption until the annual disclosures are required to be included in Form 10-K. The SEC staff also indicated that interim financial statements after the adoption should
disclose any material changes. The table of such requirements, which is an extract from the minutes of the above meeting and is available on the AICPA’s web site, is included as Attachment C to our response.

 Accordingly, the guidance for paragraph 21c. of FIN 48 required registrants to disclose the total amount of accrued interest and penalties as of the date of
adoption. We did consider whether the amount of interest and penalties recognized in the statement of income for the quarter ended March 31, 2007 was sufficiently material to require disclosure. As the amount of interest and penalties
recognized during the first quarter ended March 31, 2007 was de minimis, we concluded that our disclosures were appropriate and in accordance with the September 2006 guidance. We will continue to evaluate for future interim financial statements
for 2007 whether such interest and penalties require disclosure.

 Staff Comment No. 4:

 We note your disclosures regarding the transfer pricing uncertainty and the various other uncertain tax positions related to federal taxes which are being discussed at
the IRS Appeals level in the U.S. Tell us how you have met each of the disclosure requirements of paragraph 21d. of FIN 48 for each significant uncertain tax position.

 Company Response:

 The following table presents the disclosure requirements of paragraph 21d. and our
disclosures contained in Note 2 to our first quarter 2007 Form 10-Q. Supplemental explanatory comments are presented to aid the staff in understanding our reasoning as to why we met the disclosure requirements of paragraph 21d.

 3

 FIN 48 – Para. 21d. Disclosure

 Requirements

 Company’s Disclosure in the fifth paragraph of Note 2 and Supplemental
Explanatory
Comments

For positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly increase or decrease within 12 months of the reporting date:

 Sentence 1.

 “It is reasonably possible that
a number of uncertainties could be resolved and result in the recognition of tax benefits within the next 12 months.”

(1) The nature of the uncertainty

 Sentence 2.

 “Transfer pricing is the most
significant uncertainty, which may be resolved by entering into a revised advance pricing agreement between the U.S. and the U.K.” (Note: This position was deemed to be material.)

 Sentence 3.

 “Various other uncertain tax positions related to federal taxes are being discussed at the IRS Appeals level in the U.S.” (Note: None of these positions were deemed to be individually material.)

 Sentence 4.

 “Other less significant uncertain tax positions also may be settled of which none are individually significant.” (Note: These items were de minimis.)

(2) The nature of the event that could occur in the next 12 months that would cause the change

 Sentence 2 discusses the event (i.e., entering into a revised advance pricing agreement) that could cause a change in the amount of
unrecognized tax benefits related to the transfer pricing issues.

 Sentence 3
discusses the event (i.e., resolution of the issues at the IRS Appeals level) that could cause a change in the amount of unrecognized tax benefits for these issues.

(3) An estimate of the range of the reasonably possible change or a statement that an estimate of the range cannot be made

 Sentence 5.

 “Settlement of these matters is
not expected to have a material effect on the Corporation’s financial condition, results of operations or liquidity.” (Note: We believe that by disclosing that settlement of these matters would not have a material effect on the
Corporation’s financial condition, results of operations or liquidity that we met this disclosure requirement because our estimate of the top end of the range of reasonably possible change to the amount of unrecognized tax benefits for these
issues was not material.)

 Based upon the above, we believe that we have met the disclosure requirements for paragraph 21d of FIN 48 in our
first quarter 2007 Form 10-Q.

 4

 Attachment A

 Other Comprehensive Income (Loss)

 The changes in the components of other comprehensive income (loss) are as follows:

Year Ended December 31

2006

2005

2004

 (Millions of dollars)

Pretax
Amount

Tax
Effect

Net
Amount

Pretax
Amount

Tax
Effect

Net
Amount

Pretax
Amount

Tax
Effect

Spin
Off

Net
Amount

 Unrealized translation

$
439.7

$
—

$
439.7

$
(412.6
)

$
—

$
(412.6
)

$
415.8

$
—

$
(60.1
)

$
355.7

 Minimum pension liability

1,386.5

(498.3
)

888.2

(97.7
)

39.1

(58.6
)

(75.6
)

27.8

36.3

(11.5
)

 Unrecognized net actuarial loss and transition amount:

 Pension benefits

(1,446.5
)

508.4

(938.1
)

n/a

n/a

n/a

n/a

n/a

n/a

n/a

 Other postretirement benefits

(148.8
)

56.0

(92.8
)

n/a

n/a

n/a

n/a

n/a

n/a

n/a

 Unrecognized prior service cost:

 Pension benefits

(52.7
)

19.1

(33.6
)

n/a

n/a

n/a

n/a

n/a

n/a

n/a

 Other postretirement benefits

(25.2
)

9.6

(15.6
)

n/a

n/a

n/a

n/a

n/a

n/a

n/a

 Deferred (losses) gains on cash flow hedges

(16.4
)

5.7

(10.7
)

40.7

(13.0
)

27.7

(5.8
)

1.8

(.6
)

(4.6
)

 Unrealized holding gains (losses) on securities

.1

—

.1

.1

—

.1

(.2
)

—

—

(.2
)

 Other comprehensive income (loss)

$
 136.7

$
100.5

$
237.2

$
(469.5
)

$
26.1

$
(443.4
)

$
334.2

$
29.6

$
(24.4
)

$
339.4

 n/a – not applicable

 Accumulated balances of other comprehensive income (loss), net of applicable income taxes are as follows:

December 31

 (Millions of dollars)

2006

2005

 Unrealized translation

$
(358.2
)

$
(797.9
)

 Minimum pension liability

n/a

(888.2
)

 Unrecognized net actuarial loss and transition amount

(1,030.9
)

n/a

 Unrecognized prior service cost

(49.2
)

n/a

 Deferred gains on cash flow hedges

6.1

16.8

 Unrealized holding losses on securities

—

(.1
)

 Accumulated other comprehensive income (loss)

$
(1,432.2
)

$
(1,669.4
)

 n/a – not applicable

 Attachment B

 Accumulated Other Comprehensive Income (Loss)

 The changes in the components of accumulated other comprehensive income (loss) are as
follows:

Year Ended December 31

2006

2005

2004

 (Millions of dollars)

Pretax
Amount

Tax
Effect

Net
Amount

Pretax
Amount

Tax
Effect

Net
Amount

Pretax
Amount

Tax
Effect

Spin
Off

Net
Amount

 Unrealized translation

$
 439.7

$
—

$
439.7

$
(412.6
)

$
—

$
(412.6
)

$
415.8

$
—

$
(60.1
)

$
355.7

 Minimum pension liability

331.3

(128.0
)

203.3

(97.7
)

39.1

(58.6
)

(75.6
)

27.8

36.3

(11.5
)

 Deferred (losses) gains on cash flow hedges

(16.4
)

5.7

(10.7
)

40.7

(13.0
)

27.7

(5.8
)

1.8

(.6
)

(4.6
)

 Unrealized holding gains (losses) on securities

.1

—

.1

.1

—

.1

(.2
)

—

—

(.2
)

 Other comprehensive income (loss)

$
 754.7

$
(122.3
)

$
632.4

$
(469.5
)

$
26.1

$
(443.4
)

$
334.2

$
29.6

$
(24.4
)

$
339.4

 Adoption of SFAS 158:

 Reversal of minimum pension liability

1,055.2

(370.3
)

684.9

n/a

n/a

n/a

n/a

n/a

n/a

n/a

 Unrecognized net actuarial loss and transition amount:

 Pension benefits

(1,446.5
)

508.4

(938.1
)

n/a

n/a

n/a

n/a

n/a

n/a

n/a

 Other postretirement benefits

(148.8
)

56.0

(92.8
)

n/a

n/a

n/a

n/a

n/a

n/a

n/a

 Unrecognized prior service cost:

 Pension be