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Correspondence Letter

 April 6, 2005

 Via Edgar

 Ms. Kate Tillan

 Office of the Chief Accountant, Division of Corporation Finance, Securities and Exchange Commission

 Washington, DC 20549-0305 U.S.A.

Re:

Kyocera Corporation

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

File No. 001-07952

 Dear
Ms. Tillan:

 In response to the comments of the staff of the
Securities and Exchange Commission in your letter dated February 3, 2005 with respect to the annual report on Form 20-F of Kyocera Corporation (“Kyocera”) for the year ended March 31, 2004, we provide the following responses. For your
convenience, we have included the text of the staff’s comments below and have keyed our responses accordingly.

 As described in the responses below, in response to certain of the staff’s comments, we have agreed to revise relevant disclosures in future filings,
but any such revisions implemented in future filings should not be taken an admission that prior disclosure were in any way deficient.

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 Item 5. Operating and Financial Review and Prospects

 Results and Operation – Page 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.

 Response:

 In future filings, we will revise our analysis of results of operations to include a discussion of the structural reforms.

 Item 15. Controls and Procedures – Page 9

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.

 Response:

 In future filings, we will state clearly whether there were changes in our
internal controls over financial reporting that occurred during the relevant period and that have materially affected, or are reasonably likely to materially affect, our 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.

 Response:

 Our interest income on trade receivables and lease financings for the
year ended March 31, 2004 was approximately ¥8 billion, representing 0.70 % of our net sales for the year. In future filings, considering their significance, we will add an accounting policy for the basis of accounting for trade receivables and
lease financings and the method of recognition of interest income on each of them, as required by SoP 01-6 paragraphs 13(a)(1) and 13(a)(4).

 2

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.

 Response:

 In aggregate, revenues from the provision of services, lease of equipment and rental of real estate comprised 8.8 % of our net sales for the year ended
March 31, 2004. As such, we did not disclose revenues from these activities separately in the income statement. In future filings, if such revenues exceed 10% of our net sales, we will disclose them separately in the income statement as required by
Regulation S-X.

 In future filings, we will expand our
accounting policy on revenue recognition to include a discussion of shipping terms and significant contingencies (which, for us, are sales returns and product warranty), assumptions and estimates as follows:

 Kyocera sells various types of products, including fine ceramic parts,
semiconductor parts, and telecommunication equipment. Kyocera recognizes revenue upon completion of the earnings process, which occurs when products are shipped to the customer in accordance with the terms of an agreement of sale, there is a fixed
or determinable selling price, title and risk of loss have been transferred, and collectibility is reasonably assured. These conditions are satisfied at the time of delivery to customers in domestic sales (FOB destination) and at the time of
shipment (FOB shipping) for export sales.

 Sales returns

 Kyocera records an estimated sales return allowance at
the time of sales based on its historical returns experience.

 3

 Products warranty

 At the time of sale, Kyocera accrues a product warranty liability for claims under warranties relating to the products
that have been sold.

 Revenue from services, rental and
others

 In addition to the tangible products as
discussed above, Kyocera also provides certain services, primarily financial services provided by Kyocera Leasing Co., Ltd., (KLC), a wholly-owned subsidiary of Kyocera. Revenue from direct financing leases is recognized over the term of the lease,
and amortization of unearned lease income is recognized using the interest method. Interest income on installment loans is recognized on an accrual basis. Kyocera also enters into real estate rental transactions and rental income is recognized on a
straight-line basis over the period of the contract.

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.

 Response:

 The list on Page 77 is derived from the list of Kyocera’s objectives set forth in its Articles of Incorporation. We are currently involved in each of
the business described in items in 16 – 22, although, for the year ended March 31, 2004, in aggregate the revenues from these businesses comprised only 1.27% of our net sales. The table below sets forth the types of business described in
Kyocera’s Articles of Incorporation and the revenues from such businesses for the year ended March 31, 2004:

 (Yen in Millions)

 Article No

 Type of business

Amount of
revenue

%

1 to 15

Article 1 to 15

¥
1,126,292

98.73

16

Design, control and contract of construction relating to public works, building, electric equipment and piping construction

416

0.04

17

Sale, purchase, lease, maintenance and brokerage of real estate

2,288

0.20

18

Lease, maintenance and management of facilities relating to sports, recreation, medical care, hotels and restaurants, and the travel agency business

2,946

0.26

19

Road freight handling and

148

0.01

20

Business relating to non-life insurance agency and life insurance canvassing, and general leasing, factoring and finance business

8,016

0.70

22

Design and sale of software relating to computers

708

0.06

Total consolidated net sales

¥
1,140,814

100.00

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 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.

 Response:

 Although our policy does reference commercial notes, based on a review of our cash equivalents for the years ended March 31,
2004 and 2003, we did not have any commercial notes classified as cash equivalents. The cash and cash equivalents we currently hold are limited to bank deposits whose original maturities are less than three months. We will revise future filings to
clarify the relevant narrative disclosure in Note 1.

 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 note agree to the amounts in the consolidated statements of
stockholders’ equity. Please tell us why.

 Response:

 In response to the staff’s comment,
we note that Japanese registrants have a policy of recognizing the liability for dividends when the dividend is approved by stockholders rather than when the dividend is declared by the company. This is because the Japanese Commercial Code provides
that the company’s obligation to pay a cash dividend is fixed by the approval of stockholders at the annual stockholders’ meeting. Therefore, we reflect the dividends when approved at the annual stockholders’ meeting. This process was
is described in the Note 12, “Subsequent Events”, on Page F-37 in our Form 20-F. The actual payments are made within a few days after the annual stockholders’ meeting.

 The amount of cash dividends in the consolidated statements of stockholders’ equity only reflects the cash dividends
paid by the parent company (Kyocera). On the other hand, the amount of cash dividends paid as shown in the consolidated statements of cash flows includes the cash dividends paid by our Kyocera’s subsidiaries to their minority interests in
addition to those paid by the parent company.

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 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 Kinseki. Please tell us if you
entered into any other agreements with these companies or their shareholders in conjunction with the acquisitions.

 Response:

 Kyocera acquired Kinseki and Kyocera Chemical Corporation through statutory share exchanges under Japanese law. The exchange ratios were determined by
third party appraisers. In both cases, market values of the shares exchanged were lower than the fair value of net assets acquired.

 At the time of the announcement of these acquisitions, the view of the investors and capital markets was that each of these companies was facing financial
difficulties and would be unable, by itself, to realize the full service potential of its production facilities and other fixed assets. This resulted in the lower value of their businesses relative to the fair values of the assets acquired and
liabilities assumed.

 Kyocera determined the fair values of
the following major assets acquired and liabilities assumed as described below:

•

Inventory was valued at amounts approximating selling prices less costs to sell and a reasonable profit for the completion of the selling effort.

•

The face values less allowances for uncollectible accounts were deemed to approximate the fair values of accounts receivable because of their short-term nature.

•

Marketable securities were valued at the price quoted in stock markets.

•

Buildings and machinery were valued based on replacement costs less estimated accumulated depreciation at the time of the acquisition.

•

Lands were valued based on the land price index published by Japanese local governments.

•

The face values of current liabilities including accrued expenses and accounts payable were deemed to approximate their fair values because of their short-term nature.

•

The retirement benefit obligation was adjusted based on the current estimate of the project benefit obligations, less the fair values of the plan assets.

•

Other non-current liabilities were adjusted using current interest rates to the extent stated rates were materially different from the current rates.

 In our financial statements for the year ended March 31, 2003, the condensed
balance sheet of Kinseki included the assets and liabilities pertaining to the 28.09% interest we already owned and those pertaining to the additional 71.91% interest we acquired in 2003. The excess of net assets acquired over consideration of
¥12,157 million described in the footnote assumed that we acquired 100% of Kinseki, whereas the actual purchase price allocation was calculated for the additional 71.91%. We will revise future filings to clarify this disclosure.

 6

 The following table summarizes the purchase price allocation of Kinseki’s assets acquired and
liabilities assumed for the 71.91% additional interest acquired as of the acquisition date:

(Yen in Millions)

 Cash and cash equivalents

¥
9,860

 Trade receivables

6,108

 Inventories

3,643

 Property, plant and equipment

14,047

 Investments and other

2,897

 Trade payables

(1,773
)

 Retirement benefit obligation

(2,131
)

 Long-term borrowings

(6,246
)

 Other liabilities

(3,455
)

 Net assets acquired

22,950

 Fair value of consideration paid

15,159

 Excess of net assets acquired over consideration

¥
7,791

 The excess of net
assets acquired over consideration of ¥7,791 million was charged against property, plant and equipment.

 The following table summarizes the purchase price allocation of Kyocera Chemical Corporation’s assets acquired and liabilities assumed as of the
acquisition date:

(Yen in Millions)

 Cash and cash equivalents

¥
4,108

 Trade receivables

9,228

 Inventories

2,621

 Property, plant and equipment

18,244

 Other assets

1,143

 Trade payables

(6,209
)

 Short-term borrowings

(5,229
)

 Retirement benefit obligation

(9,153
)

 Other liabilities

(1,993
)

 Net assets acquired

12,760

 Fair value of consideration paid

9,431

 Excess of net assets acquired over consideration

¥
3,329

 The excess of