SecProbe.io

June 24, 2011
 Stephen J. Cosgrove Vice President, Corporate Controller Johnson & Johnson One Johnson & Johnson Plaza New Brunswick, NJ  08933

Re: Johnson & Johnson  Form 10-K for the Fiscal Year Ended January 2, 2011
Filed February 24, 2011 File No. 001-03215  Form 10-Q for the Quarterly Period Ended April 3, 2011 Filed May 10, 2011
Dear Mr. Cosgrove:
 We have reviewed your May 27, 2011 response to our May 3, 2011 letter and have the
following comments.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the fo rm type label CORRESP that keys your
responses to our comments.
 After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

Form 10-K for the Fiscal Year Ended January 2, 2011

 Exhibit 13

Management’s Discussion and Analysis of Re sults of Operations and Financial Condition
Income Taxes, page 38

1. Please refer to your response to our comment thr ee.  As previously requested, please provide
us proposed disclosure to be included in future filings of  the amount of cash and cash
equivalents held by foreign subsidiaries as of the latest balance sheet  date presented, which
are only available at the subs idiary level because earnings are considered permanently
reinvested.  We believe this information will provide further context with respect to your
sources of liquidity.

 Stephen J. Cosgrove Johnson & Johnson June 24, 2011 Page 2

 Form 10-Q for the Quarterly Period Ended April 3, 2011

 Notes to Consolidated Financial Statements

Note 11 – Legal Proceedings
Government Proceedings
RISPERDAL®, page 25
 2. During the quarter ended April 3, 2011, you record ed a reserve for a pot ential settlement of
the penalties under the Food Drug and Cosmetic Ac t related to Risperda l.  Please tell us:
 The amount recorded and why you believe it is a reasonable estimate of the probable
loss;  and
 Why you were unable to reasonably estimate an amount of loss or range of loss at
December 31, 2010.  In this regard, include a chronology of the facts and
circumstances from the time you filed your Form 10-K for the year ended December 31, 2010 to the date you determined an estimate of the loss.
General Litigation, page 31

3. You state that the ultimate le gal and financial liability of the Company in respect to all
claims, lawsuits and proceedings referred to above often  [emphasis added] cannot be
reasonably estimated.  We do not believe that th is disclosure meets the requirements of ASC
450-20-50-4b.  For those claims, lawsuits a nd proceedings that you can estimate, please
provide us proposed disclosure to be included in future pe riodic reports disclosing an
estimate of the possible loss or range of loss.  For those claims, lawsuits and proceedings that
you cannot estimate, please provide us proposed di sclosure to be includ ed in future periodic
reports disclosing that such an estimate canno t be made. In addition for those matters for
which you cannot estimate an amount or range, pl ease provide us with an explanation of the
procedures you undertake on a quarterly ba sis to reach that determination.

You may contact Tabatha Akin s, Staff Accountant, (202)  551-3658 or Joel Parker,
Accounting Branch Chief, at (202) 551-3651 if you have any questions regarding the comments.
In this regard, do not hesitate to contact me, at (202) 551-3679.

Sincerely,  /s/ Jim B. Rosenberg  Jim B. Rosenberg Senior Assistant Chief Accountant