SecProbe.io

Corrected
May 2, 201 4

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 31, 2013
Filed February 21, 2014
File No . 001-03215

Dear M r. Caruso :

 We have limited our review of your filing to your financial statements and related
disclosures and do not intend to expand our review to other portions of your document.   In our
comment s, 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 circumstanc es, please tell us why in your response.
Please furnish us a letter on EDGAR under the form type label CORRESP that keys your
responses to our comments.

After reviewing the information provided, we may have additional comments and/or
request that you a mend your filing.

Exhibit 13
Notes to Consolidated Financial Statements

8. Income Taxes, page 36

1. You state “ The decrease in the 2013 effective tax rate as compared to 2012 was attributable
to a tax benefit associated with the write -off of assets for tax  purposes associated with Scios
Inc., increased taxable income in lower tax jurisdictions relative to higher tax
jurisdictions…” .  Please p rovide us an analysis that explains :
 What caused the write -off of assets for tax purposes related to Scios, why the t ax benefit
was recognized in fourth quarter of 2013, and when the assets were written off for
financial reporting  purposes ; and
 What caused the increased taxable income in lower tax jurisdictions relative to higher tax
jurisdictions and whether you expect this trend to continue.

Mr. Dominic J. Caruso
Johnson & Johnson
May 2, 201 4
Page 2

19. Selected Quarterly Financial Data, page 50

2. You disclose that you recognized after -tax charges for net litigation expense of $391 million,
$308 million, $720 million and $227 million in each of the four quarters in 2013.  Tell  us:
 The nature of these expenses and confirm if they relate to product liability expenses
described in your accounting policy;
 How you determined the pre -tax amount required to be recognized in each quarter and
why such amounts were not required to be rec ognized in an earlier period;
 Why you are unable to determine an estimate of the possible loss or range of loss beyond
the amounts already accrued ; and
 Your consideration of disclosing pre -tax amounts for those items disclosed in the notes to
the table.

We urge all persons who are responsible for the accuracy and adequacy 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 compa ny 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 co mpany
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 t o 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.

You may contact Christine Torney , Staff Accountant, at (202) 551 -3652 or Lisa
Vanjoske , Assistant Chief Accountant, at (202) 551 -3614 if you have 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