SecProbe.io

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Mail Stop 3561

									November 22, 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 September 30,
2005
			Filed March 16, 2005 and November 9, 2005
			File No.  0-18761

Dear Mr. Sacks:

		We have reviewed your responses in your letter dated
November 11, 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

Notes to Consolidated Financial Statements

General

1. We read your response to comment 2 in our letter dated October
13,
2005.  We object to your proposal to change your segment reporting
beginning with your Form 10-K for the year-ended December 31,
2005.
Based on the supplemental financial reporting package you
submitted
in response to our August 1, 2005 comment letter you reported
results
to the CODM at a more detailed level than one reportable segment
for
the year ended December 31, 2004.  There appears to be no
substantive
difference, from a SFAS 131 perspective, between your segment
reporting in 2004 and currently, other than that your current
internal reporting aggregates into one operating and reportable
segment the operations of four operating segments for which
discrete
financial information was previously prepared.  In light of the
significant difference between the economic characteristics of the
DSD operating segment and the other operating segments, which are
now
aggregated and reported as the Warehouse segment, please amend
your
Form 10-K to provide all required segment information for your two
reportable segments, including product line disclosures, in an
audited note for all periods presented.  Ensure that your amended
disclosure provides all information required by paragraphs 26-28
of
SFAS 131.  Please also ensure that your amended disclosure
reconciles
each segment measure to reported consolidated amounts as required
by
paragraph 32 of SFAS 131.

Form 10-Q for the Quarter Ended September 30, 2005

Condensed Consolidated Statements of Cash Flows, page 5

2. Please tell us how you classify short-term investments for
purposes of SFAS 115.  Based on the nature of the investments you
hold as disclosed in Note 2 and the short time frame over which
investments are held we assume that you designate your short-term
investments as trading securities in accordance with paragraph
12(a)
of SFAS 115.  If so, please tell us why you classify purchases and
sales of short-term investments as investing activities on the
statements of cash flows.  Refer to paragraph 18 of SFAS 115 for
guidance.

		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
November 22, 2005
Page 3

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