SecProbe.io

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Mail Stop 3561

									August 1, 2005

Mr. Rodney C. Sacks
Chairman of the Board and Chief Executive Officer
Hansen Natural Corporation
1010 Railroad Street
Corona, California 92882

		RE:	Hansen Natural Corporation
			Form 10-K for Fiscal Year Ended December 31, 2004
			Form 10-Q for Fiscal Quarter Ended March 31, 2005
			Filed March 16, 2005 and May 10, 2005
			File No.  0-18761

Dear Mr. Sacks:

		We have reviewed your responses in your letter dated
July
15, 2005 and have the following additional comments.

		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 10-K for Fiscal Year Ended December 31, 2004

Item 6.  Selected Consolidated Financial Data, page 17

1. We read your response to comment 2 in our letter dated June 9,
2005.  We note your justification for including promotional
allowances in your non-GAAP performance measure, "Gross Sales"
however we are unclear how you have presented justification for
including estimated returns, allowances and cash discounts in the
non-GAAP measure.  Additionally, you have not disclosed the
material
limitations associated with the use of "Gross Sales" as compared
to
"Net Sales" and the manner in which management compensates for
these
limitations when using the non-GAAP financial measure.  Refer to
Question 8 of the Frequently Asked Questions Regarding the Use of
Non-GAAP Financial Measures, which is available on our website at
www.sec.gov.  We believe an alternative way to inform investors of
your sales volumes and impact promotional allowances had in
operations would be to quantify the amount of cans or bottles sold
for the various fiscal periods and disclose the amount of
promotional
allowances included in arriving at "Net Sales" in your MD&A
discussion similar to your disclosure on page 57 under the caption
Advertising and Promotional Allowances.

Notes to Consolidated Financial Statements

General

2. We read your response to comment 7 in our letter dated June 9,
2005.  Product line revenue disclosures should identify products
from
which each reportable segment derives its revenue and should
mirror
the financial information used to prepare your general-purpose
financial statements.  Please tell us the product categories
reported
to senior management in daily, weekly or monthly sales reports for
purposes of managing the business.  Please note that if providing
disclosure of product line revenue information is impracticable
you
should so state in accordance with paragraph 37 of SFAS 131.
Also,
refer to Section II.J.3. of the Current Accounting and Disclosure
Issues in the Division of Corporation Finance updated March 4,
2005
and available on our website at www.sec.gov.

Segment Information, page 59

3. We read your response to comment 12 in our letter dated June 9,
2005.  With regard to your request to disclose one reportable
segment
we refer you to paragraphs 109-111 of SFAS 131, which address
concerns about competitive harm.  Please note that SFAS 131 does
not
require an enterprise to report information that is not prepared
for
internal use if reporting it would be impracticable.  From your
response we fail to see how reporting the required SFAS 131
disclosures would be impracticable for you since the information
is
prepared internally and that is the way your reportable segments
are
being managed.  In order to better understand how you concluded
that
you only have two reportable operating segments, please provide us
the following:
* The name and position of your chief operating decision maker;
* A complete copy of the year end and a recent monthly internal
management report provided to your chief operating decision maker
that includes your operating results;
* A copy of the package given to the Board of Directors for the
same
time periods; and
* An organizational chart detailing your management structure
under
the chief operating decision maker as it relates to managing the
operational aspects of your business.
Additionally, please tell us the measure(s) that your CODM uses to
evaluate and allocate resources to your operating segments.  For
each
measure that you list, as well as for revenues and gross margin,
please provide us your computation of these measures for the last
five years and demonstrate how that information supports the
similarity of the economic characteristics of the operating
segments.
If after reassessing the criteria in SFAS 131, you now believe
that
you have separate reportable segments, please revise your future
financial statements accordingly.

		As appropriate, please respond to these comments within
10
business days or tell us when you will provide us with a response.
Please ensure the response letter provides any requested
supplemental
information.  Please file your response letter on EDGAR.  Please
understand that we may have additional comments after reviewing
your
response to our comments.

		If you have any questions regarding these comments,
please
direct them to Anthony Watson, Staff Accountant, at (202) 551-3318
or, in his absence, to me at (202) 551-3843.

									Sincerely,

									George F. Ohsiek, Jr.
									Branch Chief
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Mr. Rodney C. Sacks
Hansen Natural Corporation
August 1, 2005
Page 3

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