SecProbe.io

June 1, 2012

Via E -mail
Mr. Dominic J. Caruso
Chief Financial Officer
Johnson & Johnson
One Johnson & Johnson Plaza
New Brunswick, NJ 08933

Re:  Johnson & Johnson
Form 10 -K for the Fiscal Year Ended January 1 , 201 2
Filed February 23, 2012
Form 10 -Q for the Quarterly Period  Ended April 1 , 201 2
Filed May 7 , 2012
  File No.  001-03215

Dear Mr . Caruso :

We have limited our review to only your financial statements and related disclosures and
do not intend to expand our review to other portions of your document s.  In our comments, we
ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 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 form type label CORRESP that key s your
response s to our comments.

After reviewing the information you pr ovide in response to these comments , we may
have  additional comments  and/or request that you amend your filing s.

Form 10 -K for the Annual Period Ended January 1, 2012
Exhibit 13

Results of Operations
Analysis of Consolidated Earnings Before  Provisions for Taxes on Income, page 29

1. Please provide us proposed disclosure to be included in future periodic filings  that quantifies
the individual items that impact the changes for the three years presented. You state that the
decrease in consolidate d earnings was due to costs associated with product liability and
litigation expense, the impact of the OTC and DePuy Hip recalls and the restructuring
expense related to the Cardiovascular Care business and that it was also impacted by
investment spending , the fee on branded pharmaceutical products incurred due to U.S. health

Mr. Dominic J. Caruso
Johnson & Johnson
June 1, 2012
Page 2

 care reform and integration costs associated with the acquisition of Crucell. You should
consider a tabular presentation.   Please also apply this to other sections of the Results of
Operations  such as but not limited to: cost of products sold, selling, marketing and
administrative expenses and research and development expenses.

Concentration of Credit Risk, page 32

2. You disclose that recent economic challenges in Italy, Spain, Greece and Portugal have
impacted certain payment patterns. Please tell us the following information:
 The amount of sales in 2011 and accounts receivable as of January 1, 2012 and April 1,
2012 by country from Italy, Spain, Greece and Portugal separately by amoun ts
from/funded by each country’s government;
 The amount past due from each of those countries and the number days of past due
separately by amounts from/funded by each country’s government; and
 The amount of allowance for doubtful accounts recognized at Ja nuary 1, 2012 and April
1, 2012 related to these countries and why you believe the amounts to be adequate.

Note 1. Summary of Significant Accounting Policies
Research and Development, page 43

3. During our review of your Form 10 -K for the Fiscal Year Ended January 2, 2011 in your
response dated May 27, 2011, you stated that you would enhance your disclosure to clarify
that no individual research and deve lopment investment is material  to your conso lidated
operating results, for as long as that remains the case.   If this is still the case, please confirm
this and provide us proposed disclosure to be included in future periodic filings  that clarifies
this fact.

Income Taxes, page 43

4. During the pri or SEC staff review of your Form 10 -K for the Fiscal Year Ended January 2,
2011 you provided us proposed disclosure to include in future filings which addressed the
disclosure required under ASC 740 -30-50-2c.  Please confirm that you will include
disclosur e in future filings which discloses the amount of the unrecognized deferred tax
liability for temporary differences related to investments in foreign subsidiaries or state that
the determination of the liability amount is not practicable.

Form 10 -Q for th e Quarterly Period ended April 1, 2012
RISPERDAL®, page 19

5. You disclose on page 20 of your filing that you did not establish an accrual for the verdicts
against you in the RISPERDAL® trials with the State of Arkansas, the State of South
Carolina and the S tate of Louisiana. The verdicts were approximately $1.2 billion, $327.1
million and $330.7 million, respectively. Please tell us how, given that thi s was the third state
judgment against you , there are ongoing settlement discussion with the federal governm ent
regarding the off -label promotion of this drug and your settlement with the State of Texas,

Mr. Dominic J. Caruso
Johnson & Johnson
June 1, 2012
Page 3

 you determined that the potential for an unfavorable outcome is not probable. Specifically
address why you believe it is probable that the verdicts will be over turned.

6. You disclose “In 2011, the Company established an accrual with respect to the above state
matters.”  Please provide us proposed disclosure to be included in future periodic filings that
clarifies which state matters this disclosure refers to since  several matters state that no
accrual has been made.

We urge all persons who are responsible for the accuracy and a dequacy of the disclosure
in the se filing s to be certain that the filing s include the information the Securities Exchange Act
of 1934 and a ll applicable Exchange Act rules require.   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 responding to our  comments, please provide  a written statement from the company
acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclosure in the
filing s;
 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any  action with respect to the se filing s; 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.

You may c ontact Dana Hartz, Staff Accountant, at (202) 551 -3648 or Lisa Vanjoske ,
Assistant Chief Accountant , at (202) 551 -3614 if you have questions regarding these 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