SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 4720                                                                                                   June 8, 2009   Mr. W. C. Weldon Chairman, Board of Directors, and Chief Executive Officer Johnson & Johnson One Johnson & Johnson Plaza New Brunswick, New Jersey 08933
Re: Johnson & Johnson
Form 10-K for the Period Ended December 31, 2008 Filed February 20, 2009
 File No. 001-03215

Dear Mr. Weldon:

 We have reviewed your filing and have the following comments.  In our
comments, we ask you to provide us with  information to better understand your
disclosure. Where a comment requests you to  revise disclosure, the information you
provide should show us what the revised disc losure will look like and identify the annual
or quarterly filing, as applicab le, in which you intend to firs t include it.  If you disagree,
we will consider your explanation as to why our comments are inapplicable or a revision
is unnecessary.  After reviewing the info rmation provided, we may raise additional
comments and/or request that you amend your filing.   Please understand that the purpose of our re view 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.
Exhibit 13

Management’s Discussion and Analysis of Re sults of Operations and Financial Condition
Liquidity and Capital Resources
Contractual Obligations and Commitments, page 40

1. Please revise your contractual obligations table to include  interest expense since it
is part of your contractual obligation of debt.

Mr. W. C. Weldon
Johnson & Johnson June 8, 2009 Page 2
 Consolidated Financial Statements

Notes to Consolidated Financial Statements
Summary of Significan t Accounting Policies
Revenue Recognition, page 49

2. Refer to your disclosure “sal es returns allowances repr esent a reserve for products
that may be returned due to expiration, de struction in the field, or in specific
areas, product recall.”  Revise your disclosure to address:
• Whether you refund the sales price by i ssuing cash or a credit, or whether
you exchange product from your inventory for the returned product;
• Whether the returned product is resalable; and,
• If you exchange product from your i nventory for the returned product,
how you account for your estimate of returns at the time of the product sale and how you account for returns when  they are actually returned and
make the exchange.  Provide us an  analysis supporting your accounting
treatment with reference to authoritativ e literature.  It also may be helpful
to provide us an example showing the journal entries made.

*    *    *    *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that  keys your responses to our
comments and provides the requested information.  Detailed letters greatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 co mments, please provide, in your letter, 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

Mr. W. C. Weldon
Johnson & Johnson June 8, 2009 Page 3
 In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
Please contact Kei Ino, Staff Accountant,  at (202) 551-3659 or Gus Rodriguez,
Accounting Branch Chief, at (202) 551- 3614, if you have questions regarding these
comments.  In this regard, do not hes itate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant