SecProbe.io

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October 29, 2004

Mail Stop 0510

via U.S. mail and facsimile

Mr. Donald E. Washkewicz
President and Chief Executive Officer, Parker-Hannifin Corporation
6035 Parkland Boulevard
Cleveland, OH  44124-4141

	RE:	Form 10-K for the fiscal year ended June 30, 2004
		Filed September 3, 2004
File No. 1-04982

Dear Mr. Washkewicz:

		We have reviewed your filing and have the following
comments.  Where indicated, we think you should revise your document
in response to these comments.  If you disagree with a comment, 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 10-K for the Year ended June 30, 2004

Item 7. Management`s Discussion and Analysis of Financial Condition
and Results of Operations.

General

1. In future filings, expand your Management`s Discussion and Analysis
section to better inform investors of current trends and risks faced
by the company from management`s perspective.  Also quantify in more
detail your results of operations to help readers better understand
changes from one year to the next.  For example, quantify the material
components that impacted the change in sales and margins year over
year.  Refer to Release No. 33-8350: Interpretation - Commission
Guidance Regarding Management`s Discussion and Analysis of Financial
Condition and Results of Operations.

Contractual Obligations

2. In future filings, include your interest commitments under your
interest-bearing debt in this table, or provide textual discussion of
this obligation below the table.  If you provide a textual discussion,
the discussion should quantify the interest payments using the same
time frames stipulated in the table.  In addition, include the other
long-term liabilities reflected on your balance sheet under generally
accepted accounting principles, such as those related to your pension
plans and postretirement medical and life insurance benefits.  Refer
to footnote 46 to Release 33-8350 "Interpretation: Commission Guidance
Regarding Management`s Discussion and Analysis of Financial Condition
and Results of Operations."

Critical Accounting Policies

3. Expand your discussion of pensions to discuss the future potential
impact that your unrecognized actuarial loss will have on future
financial statements.

Item 8. Financial Statements and Supplementary Data

Note 1. Significant Accounting Policies - Long-term Contracts

4. In future filings, disclose the method of measuring the extent of
progress toward completion.  Refer to paragraph 45 of SOP 81-1.

Note 6. Inventories

5. You indicate in your critical accounting policies that inventories
have been reduced by an allowance for excess and obsolete inventories.
Given your reference to this management estimate, in future filings
provide a rollforward of this allowance herein or in Schedule II -
Valuation and Qualifying Accounts.

Note 7. Goodwill and Intangible Assets

6. You disclose that your 2004 impairment charge was recorded in the
Industrial Segment primarily resulting from declining market
conditions and lower future growth potential.  However, we note your
statements in Management Discussion & Analysis that the Industrial
North American markets saw "continued improvement" and "this trend to
continue into 2005".  Also, you disclose that the Company expects
sales and profits in the Asia Pacific and Latin American regions to
grow.  In future filings, please explain in further detail the reasons
for the goodwill impairment and provide sufficient information to
reconcile these disclosures.

Note 14. Research and Development

7. We note that you net the revenues you have earned under research
and development contracts against your research and development costs.
Differentiate for us your accounting for (i) research and development
contracts with the federal government, if any, and (ii) research and
development contracts for other customers.  Provide the authoritative
literature that supports your accounting for each of these types of
contracts.  In future filings, provide the disclosures required by
paragraph 3.56 of AICPA Audit and Accounting Guides - Audit of Federal
Government Contractors.

Note 15. Contingencies

8. In future filings, provide a rollforward of your accrued
environmental liabilities.  In addition, to the extent any of the 28
manufacturing facilities represents a material component of your
accrual or the maximum amount of your range of loss, consider the need
to provide additional footnote and MD&A disclosures contemplated by
Questions 2, 3 and 4 of SAB Topic 5Y.

*    *    *    *

Please respond to these comments within 10 business days, or tell us
when you will provide us with a response.  Please provide us with a
supplemental response letter that keys your responses to our comments
and provides any requested supplemental information.  Detailed letters
greatly facilitate our review.  Please file your supplemental response
on EDGAR as a correspondence file.  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 filings 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.

If you have any questions regarding these comments, please direct them
to Ryan Rohn, Staff Accountant, at (202) 824-5525 or, in his absence,
to Jeanne Baker, Assistant Chief Accountant at (202) 942-1835, or the
undersigned at (202) 942-1798.

							Sincerely,

							John Hartz
							Senior Assistant Chief Accountant

PARKER-HANNIFIN CORPORATION
October 29, 2004
Page 4 of 4

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

       DIVISION OF
CORPORATION FINANCE

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