SecProbe.io

March 28, 201 3

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 December 30,  2012
Filed February 22, 2013
  File No.  001-03215

Dear Mr. Caruso:

We have reviewed your filing and have the following comments.  In some of our
comments, we  may ask you to provide us with information so we may better understand your
disclosure .

Please respond to this letter within 10 business days by amending your filing, providing
the requested information or by advising us when you will provide the requested response.  If
you do not b elieve a n amendment is appropriate or that 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 comment s.

After reviewing the amended filing and the information you provide in response to th ese
comment s, we may have additional comments .

Business
Patents and Trademarks, page 2

1. We note your statement on page 2 that you believe the patents related to REMICADE® are
material to the c ompany.   Please amend your disclosure to explain:
 whether you own or license these patents, and from whom you license them, if
applicable;
 the material jurisdictions in which you hold these patents ; and
 the expiration  dates of these patents .
In addition , please describe your anticipated response to the loss of protection, including for
example, any plans to apply for exclusivity extensions and the basis for such actions. If you
do not intend to take any such actions please disclose that as well.

Mr. Dominic J. Caruso
Johnson & Johnson
March 28, 201 3
Page 2

Exhibit 13
Notes to Consolidated Financial Statements
Note 20.  Business Combinations and Divestitures, page 50

2. Throughout your note, you reference to purchase price allocations.  Please tell us how using
purchase price allocation complies with the acquisition met hod as described in ASC 805.

3. Please explain to us your basis for concluding that the estimated useful life of the Synthes
amortizable intangibles was a weighted average of 21 years.  Please breakout this analysis
between customer relationships and patents  and technology.

We urge all persons who are responsible for the accuracy and a dequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all 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 comment s, 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;
 staff comments or changes  to disclosure in response to staff comments do not
foreclose the Commission from taking any  action with respect to this  filing; and
 the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under th e federal securities laws of the United
States.

You may c ontact Dana Hartz, Staff Accountant, at (202) 551 -3648 or Joel Parker ,
Accounting Branch Chief , at (202) 551 -3651 if you have questions regarding the processing of
your response as well as any quest ions regarding comments on the financial statements and
related matters.  Please contact Amy Reischauer , Staff Attorney,  at (202) 551 -3793 or Jeffrey P.
Riedler , Assistant Director,  at (202) 551 -3715 with questions on comment one .  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