SecProbe.io

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February 3, 2005

Mail Stop 0306

Mr. Hideki Ishida
Managing Executive Officer
Kyocera Corporation
6, Takeda, Tobadono-cho, Fushimi-ku
Kyoto, Japan 612-8501

Re:
	Annual Report on Form 20-F
      Filed September 21, 2004
	File No. 001-07952

Dear Mr. Ishida:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents. Where indicated, we think you should revise your future
filings in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 20-F for the year ended March 31, 2004

Item 5. Operating and Financial Review and Prospects

Results of Operations - Pages 33 to 44

1. We note in your 6-K filed on October 28, 2004 that you began
the
implementation of structural reforms in the first half of 2005 in
order to reorganize your optical instruments business, which led
to
recording approximately 1.9 billion yen in operating expenses in
the
six months ended September 30, 2004 (increasing to approximately
7.6
billion yen for the full year 2005).  In future filings, if such a
plan has been implemented and the amount is material, please
revise
your analysis of results of operations to include a discussion of
the
structural reforms.

Item 15. Controls and Procedures - Page 93

2. We note your disclosure that "Except as noted above, no change
in
internal control over financial reporting (as defined in Rules
13a-
15(f) under the Securities Exchange Act of 1934) occurred during
year
ended March 31, 2004 that has materially affected, or is
reasonably
likely to materially affect, Kyocera`s internal control over
financial reporting."  In future filings, if correct, please
revise
to state clearly that there were changes in your internal control
over financial reporting that occurred during the period that have
materially affected, or are reasonably likely to materially
affect,
your internal control over financial reporting.

Notes to The Consolidated Financial Statements

Note 1. Accounting Policies

General

3. Consider revising future filings to include an accounting
policy
for the basis of accounting for trade receivables and lease
financings.  Refer to paragraphs 13(a)(1) and 13(a)(4) of SOP 01-
6.

Revenue Recognition - Page F-7

4. Your accounting policy for revenue recognition should be
specific
to the company and not just provide general revenue recognition
rules. The policy should include material assumptions and
estimates,
material changes, reasonably likely uncertainties and significant
quantitative information about revenues. We note that you sell
your
products to distributors, wholesalers, manufacturers and end users
and that you record revenue from the sale of products, provision
of
services, lease of equipment and rental of real estate.  You
should
disclose, if applicable, revenues from such activities (and cost
of
such revenues) on the face of the income statement. Please refer
to
Items 5-02(b)(1)&(b)(2) of Regulation S-X.  We note that revenues
from three of your segments are principally recognized upon
delivery
to customers.  You should indicate whether your shipping terms are
customarily FOB shipping point or FOB destination. Do you only
record
revenue upon transfer of title, or are there situations where this
is
not the case? Please explain. Why do you use the term "generally"?
Disclose contingencies such as rights of return, conditions of
acceptance, warranties, price protection, etc. and describe how
you
account for them.  Please provide this information supplementally
and
in future filings.
5. We note the objects of Kyocera Corporation as set forth on page
77. Your current revenue recognition policy does not address
accounting for revenues from the objects listed in 16 - 22. Please
tell us whether or not you are involved in these businesses and,
if
so, please quantify the revenues from each object for fiscal 2004.

Cash and cash equivalents - Page F-7

6. Cash equivalents are short-term, highly liquid investments that
are both readily convertible to known amounts of cash and so near
their maturity that they present insignificant risk of changes in
value because of changes in interest rates. See paragraph 8 of
SFAS
95. Please tell us why it is appropriate under SFAS 95 to classify
short-term commercial notes as a cash equivalent.

Earnings and Cash Dividends per Share - Page F-10

7. Dividends declared on stock that is accounted for as equity
should
generally be reflected as a liability when declared. We note that
you
reflect the dividends when paid. Please tell us why and cite the
accounting literature upon which you relied. We also note that the
reported amount of cash dividends paid in the consolidated
statements
of cash flows does not agree to the amounts in the consolidated
statements of stockholders` equity.  Please tell us why.

Note 3. Business Combinations - Page F-12

8. Please tell us and disclose in future filings the significant
factors that contributed towards a purchase price less than the
fair
value of the net assets of 12,157 million yen for Kinseki and
3,329
million yen for Kyocera. Please explain to us how you determined
the
estimated fair values of each significant asset or liability
acquired. Please show us and revise future filings to include the
disclosures required by paragraphs 51(e) and 52 of SFAS 141. We
note
that the estimated fair value of the net assets acquired for each
company equals the total book value of the net assets of each
company
and that you only acquired 71.91% of Kineski. Please tell us if
you
entered into any other agreements with these companies or their
shareholders in conjunction with the acquisitions.
9. We note your disclosure that the results of operations for KCC
before your investment included in the pro forma amounts reflect
balances calculated in accordance with Japanese GAAP. It does not
appear appropriate to combine U.S. GAAP financial statements with
Japanese GAAP financial statements to prepare the pro forma data
required by SFAS 141. Please revise in future filings, or tell us
why
the current presentation is appropriate.

Note 5. Finance Receivables - Page F-16

10. We note that you have other finance receivables of 84,254
million
yen as of March 31, 2004, net of an allowance for doubtful
accounts
of 35,937 million yen, or 19% of the gross amount of those
receivables. Footnote (b) to the table on page F-16 states that
other
finance receivables consist primarily of installment loans to
affiliates and other parties. Please respond to the following
comments:
* Please tell us and quantify the significant components of your
other finance receivables.
* Please tell us the nature and amount of installment loans to
affiliates. Explain the nature of the affiliate relationship. Tell
us
why you have not separately disclosed these related party loans.
* Please tell us the nature of the allowance for doubtful
accounts.
That is, we note the amount of the provision charged to income in
each of the last three years was relatively small compared to the
balance in the allowance account.
* Please tell us the nature of the charge-off of 13,763 million
yen
in fiscal 2004.

Note 11. Stock Options Plans - Page F-25

11. Revise future filings to clarify the general terms of awards
under your domestic stock option plan in accordance with paragraph
46
of SFAS 123.  It is not clear in the current presentation when the
awards granted in 2004 vest, become exercisable and expire.
12. It appears that you may have canceled options in fiscal 2004
and
re-issued options at a lower exercise price. We note that you
granted
1,068,900 options in 2004 and cancelled 1,366,900 options. Please
explain and tell us how you accounted for the issuances and why.

Note 16. Income Taxes - Page F-31

13. In regard to your undistributed earnings of your subsidiaries
and
affiliates, please revise future filings to include the
disclosures
required by paragraph 44 of
SFAS 109.
14. We note that if the earnings of foreign subsidiaries and
affiliates are remitted, it would result in nominal tax by
utilization of available foreign tax credits.  Please tell us and
describe in future filings the nature and amount of your available
foreign tax credits.
15. We note your claim that 60% of your net operating loss
carryforwards will not expire.   Please tell us and disclose in
future filings the nature of these NOL carryforwards and why you
believe they have an infinite life.

Note 18. Segment Reporting - Page F-33

16. Please tell us the nature of the organization of the reports
reviewed by your CODM under SFAS 131 and explain how you
determined
your reportable segments.

* * * * *

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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 connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure 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
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

      You may contact Tom Dyer, Staff Accountant, at (202) 824-
5564
or me at (202) 942-2861 if you have any questions.  In this
regard,
do not hesitate to contact Daniel Gordon, Branch Chief, at (202)
942-
2813.

							Sincerely,

							Kate Tillan
							Reviewing Accountant

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Mr. Hideki Ishida
Kyocera Corporation
February 3, 2005
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