SecProbe.io

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           					August 2, 2005

By U.S. mail and facsimile to 011 44 (0) 20 7717 4455

David Lloyd
Executive Director, Finance
Corus Group plc
30 Millbank
London SW1P 4WY
England

	RE:	Corus Group plc
		Form 20-F for the fiscal year ended January 1, 2005
		Filed March 31, 2005

		File No. 1-10120

Dear Mr. Lloyd:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your disclosures in
future
filings in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise
additional comments.

	Please understand that the purpose of our review 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.

Form 20-F for the fiscal year ended January 1, 2005

Aggregate contractual arrangements, page 30
1. We note that your tabular debt maturity profile does not
include
the interest commitments related to your debt.  Include the
interest
commitments under your interest-bearing debt in this table, or
provide
textual discussion of this obligation in the footnotes to the
table.
If you provide a textual discussion, the discussion should
quantify
the interest payments using the same time frames stipulated in the
table.  Refer to footnote 46 to Release 33-8350.

Item 15 Controls and Procedures - Disclosure controls and
procedures,
page 46
2. We note that your Chief Executive Officer and Chief Financial
Officer concluded your disclosure controls and procedures "...were
effective in providing reasonable assurance that the information
required to be disclosed by Corus in reports that it files under
the
US Exchange Act of 1934, as amended, is recorded, processed,
summarized and reported within the time periods specfied by the
rules
and the forms of the US Securities and Exchange Commission."  This
is
an incomplete definition of disclosure controls and procedures per
Rules 13a-15(e) and 15d-15(e) of the Exchange Act.  Please revise
your
disclosure to clarify, if true, that your officers concluded that
your
disclosure controls and procedures are effective to ensure that
information required to be disclosed by you in the reports that
you
file or submit under the Exchange Act is recorded, processed,
summarized and reported, within the time periods specified in the
Commission`s rules and forms and to ensure that information
required
to be disclosed by an issuer in the reports that it files or
submits
under the Exchange Act is accumulated and communicated to your
management, including its principal executive and principal
financial
officers, or persons performing similar functions, as appropriate
to
allow timely decisions regarding required disclosure.  Otherwise,
please simply conclude that your disclosure controls and
procedures
are effective or ineffective, whichever the case may be.

Report & Accounts 2004

Accounting policies, pages 50 -51
3. We note your belief that your accounting for provisions of
retirement benefits for employees, redundancy and rationalisation
include areas of judgment that relies upon a number of estimates
and
is subject to uncertainties.  In addition, we note that these
areas of
judgment can vary between different countries in which the Group
operates and there is a large degree of inter-dependency between
the
countries, and as of result of these factors, no analysis is given
of
a change in any one particular assumption.  We believe that this
analysis is necessary for a reader`s understanding of your
critical
accounting policies.  We believe your discussion of the fact that
there are a number of elements used in the assumptions, that they
vary
for the different countries in which the Group operates and there
may
be inter-dependency between some assumptions is a helpful reminder
to
readers that they should not view the impact of a change in
individual
assumptions in isolation.

Presentation - II Basis of consolidation, page 89
4. We note your risk factor on page 3 of your Form 20-F that
certain
business decisions concerning Corus Nederland requires the
approval by
the Corus Nederland Supervisory Board, a body whose composition is
not
wholly within the control of Corus and that this Supervisory Board
has
previously withheld its approval of a key strategy decision of
Corus
Group.  We also note that, notwithstanding this Supervisory Board,
Corus Nederland has been included in the consolidated financial
statements of Corus Group as a wholly owned subsidiary
consolidated
under UK GAAP.  Tell us what consideration you gave to the
appropriateness of consolidating this subsidiary under US GAAP
given
the significant decisions that are subject to the Supervisory
Board
decisions.  Refer to SFAS 94.

5.  	Describe the difference between the gross equity method and
equity method of consolidation as it relates to your joint
ventures
and associated undertakings.  Address any US GAAP reconciling
information.

Presentation - III Turnover, page 89

6.  	Clarify herein or Note 38 - Supplementary information for
North
American investors when the significant risk and rewards of
ownership
have passed.  If, in accordance with SAB Topic 13.A.1, it is not
when
delivery has occurred, please provide any necessary reconciling
information for US GAAP purposes.

Presentation - IV Rationalisation and related measures and
environmental remediation, page 89

7.  	Clarify herein or Note 38 - Supplementary information for
North
American investors that your accounting meets the recognition and
measurement requirements of SFAS 146.  In addition, provide all
the
disclosures required by paragraph 20 of SFAS 146.

Presentation - VII Insurance, page 89

8.  	Clarify herein or Note 38 - Supplementary information for
North
American investors what is meant by "accounted for on an annual
basis"
with regard to your insurance business and how you determine the
appropriate level of insurance provisions with regard to your
marine
cargo and certain employer`s liability.  Confirm that incurred but
not
reported claims are appropriately taken into account with regard
to
all the company`s insurance provisions for US GAAP purposes.

Presentation -- XI  Derivative financial instruments, page 90

9.  	Disclose herein or Note 38 - Supplementary information for
North
American investors your specific methodology used to test hedge
effectiveness, and how often those tests are performed.  For US
GAAP
purposes, compliance with SFAS 133 should be clearly evident.

Presentation - XIII Tangible fixed assets, page 90

10.  Clarify the nature of commissioning costs and address the
appropriateness of expensing them as incurred for US GAAP
purposes.

Presentation - XV Fixed asset investments, page 91

11.  Tell us more about Corus Group plc`s acquisition of Corus UK
Limited in 1999 under a Scheme of Arrangement.  It is our
understanding that for US GAAP purposes, this transaction would be
accounted for as a reorganization of entities under common
control.
Tell us what you mean by your disclosure that the investment in
Corus
UK Limited is recorded at the aggregate value of the nominal value
for
shares issued to acquire the investment and fair value of other
consideration given.  Tell us how this accounting complies with US
GAAP.

26.1  Share capital of the Company, page 113

12. 	We note that prior to the offering of 1,304 million new
ordinary
shares on the basis of five new ordinary shares of 10p each per 12
existing ordinary shares of 50p held, the existing issued ordinary
shares were subdivided and converted from one existing ordinary
share
of 50p into one ordinary share of 10p and one deferred share of
40p.
Expand your disclosure herein or Note 38 - Supplementary
information
for North American investors to clarify how this transaction
impacted
your earnings per share (ADS) for US GAAP purposes.  It is unclear
to
us whether this transaction is akin to a stock split for US GAAP
purposes.

32.  Pensions and post retirement benefits, pages 120 - 127

13. 	Based on your disclosures herein and Note 38, it appears that
you
have provided  a US GAAP adjustment related to your BS, CES, SPH
and
CNG pension plans.   Clarify for US GAAP readers why it was not
necessary to provide a reconciling adjustment related to your
other
pension plans.  In this regard, we note you recognized GBP25
million
in 2004 for pension plans other than the BS, CES, SPH and CGN
pension
plans for UK GAAP purposes with no apparent US GAAP adjustment.

38.  Supplementary information for North American investors, page
133

14.  For ease of US GAAP readers, please consider providing a
schedule
that rolls forward shareholders` equity under US GAAP for each
period
presented.

*    *    *    *

      Please respond to these comments by providing the
supplemental
information requested within 10 business days or tell us when you
will
provide us with a response.  Please provide us with a supplemental
response that addresses each of our comments.  Please file your
supplemental response on EDGAR as a correspondence file.  We may
raise
additional comments after we review your responses.

      To expedite our review, you may wish to provide complete
packages to each of the persons names below.  Each package should
include a copy of your response letter and any supplemental
information.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they provided all information investors 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 connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* 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 comments as a defense in any
proceeding initiated by the Commission or any person under the
federal
securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in our review of your filing or in response
to
our comments on your filing.

      You may contact Jenn Do, Staff Accountant, at (202) 551-
3743,
Jeanne K. Baker at (202) 551-3691 or me at (202) 551-3689 if you
have
questions regarding comments on the financial statements and
related
matters.

								Sincerely,

								John Hartz
Senior Assistant Chief Accountant

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Mr. David Lloyd
Corus Group plc
August 2, 2005
Page 6

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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