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July 27, 2010  Carlos Salazar Lomelin, Chief Executive Officer Coca-Cola FEMSA, S.A.B.de C.V. Guillermo Gonzalez Camarena No. 600 Centro de Cuidad Santa Fe 01210 Mexico, D.F. Mexico               RE:  Coca-Cola FEMSA, S.A.B. de C.V.
                      Registration Statement on Form F-4
                      File No. 333-168109                       Filed July 15, 2010

Dear Mr. Lomelin:
     We have limited our review of your re gistration statement to those issues we have
addressed in our 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 by amendi ng your registration statement and providing
the requested information.  Where you do not be lieve our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information
you provide in response to these comment s, we may have additional comments.
 General

1. We note that you are registering the exch ange notes in reliance on our position
enunciated in Exxon Capital Holdings Cor p., SEC No-Action Letter (April 13, 1988).
See also Morgan Stanley & Co. Inc., SEC No -Action Letter (June 5, 1991) and
Shearman & Sterling, SEC No-Action (July 2, 1993).  Accordingly, with the next
amendment, please provide us with a supplemental letter st ating that you are
registering the exchange offer in relian ce on our position contained in these letters
and include the representations contained in the Morgan Stanley and Shearman &
Sterling no-action letters.

Carlos Salazar Lomelin
Coca-Cola FEMSA, S.A.B.de C.V. July 27, 2010 Page 2  Closing Comments

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that th e filing includes the information the Securities Act
of 1933 and all applicable S ecurities Act rules require.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request accelerati on of the effective
date of the pending registration statement pl ease provide a written statement from the
company acknowledging that:

• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose th e Commission from taking any action with
respect to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective,  does not relieve the company from its full responsibility
for the adequacy and accuracy of th e disclosure in the filing; and

• the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.  Please refer to Rules 460 and 461 regard ing requests for acceleration.  We will
consider a written request for acceleration of th e effective date of th e registration statement
as confirmation of the fact that those request ing acceleration are aware of their respective
responsibilities under the Securi ties Act of 1933 and the Securiti es Exchange Act of 1934 as
they relate to the proposed public offering of th e securities specified in  the above registration
statement.  Please allow adequate time for us to review any amendment prior to the requested
effective date of the regist ration statement.
   Please contact Janice McGuirk, examiner  at (202) 551-3395 or David Link, legal
reviewer, at (202) 551-3 356 with any questions.

Sincerely,
     John Reynolds,
Assistant Director
 cc:   via fax to Jaime A. El Koury, Esq.                        (212) 225- 3999

Carlos Salazar Lomelin
Coca-Cola FEMSA, S.A.B.de C.V. July 27, 2010 Page 3