SecProbe.io

August 19, 2011
 Via E-Mail

Hèctor Trevi ňo Gutièrrez
Chief Financial Officer Coca-Cola FEMSA S.B.A. de C.V. Guillermo González Camarena No. 600 Centro de Ciudad Santa Fé 01210 México, D.F., México
Re: Coca-Cola FEMSA S.A.B. de C.V.
 Form 20-F for Fiscal Year Ended December 31, 2010
Filed June 17, 2011 File No. 001-12260

Dear Mr. Trevi ňo Gutièrrez:
 We have reviewed your filing and have the following 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 within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
 Form 20-F for Fiscal Year Ended December 31, 2010

 Item 5. Operating and Financial Review Prospects, page 40

 Consolidated Results of Operati ons by Reportable Segment, page 49

 1. Please expand management’s discussion and an alysis of your Venezuelan operations to
provide a more comprehensive discussion that provides a greater level of information about
the monetary assets and liabili ties that are exposed to ex change rate changes and the
sensitivity of your sales and cost of sales to  future currency changes.  Include in your
discussion how government actions regarding exchange rates and related restrictions affect
your ability to settle transacti ons and to repatriate cash. Also disclose anticipated or recent
changes to your business practices or policies arising from the economic conditions in Venezuela.

Hèctor Trevi ňo Gutièrrez
Coca-Cola FEMSA S.A.B. de C.V. August 19, 2011 Page 2

2. In order to assist an invest or’s understanding, please supplem ent the above discussion with
disaggregated financial inform ation including summarized balance sheets, income statements
and cash flows for your Venezuelan operations . Disclose the specific amount of Bolivar-
denominated monetary assets and liabilities as of each balance sheet date and a schedule of
the amounts being re-measured at each exchange rate.  Also disclose the amount for cash and
accounts receivable, sales, costs of sales and operating profit for Venezuela and separately
disclose the amounts denominated in Bo livar fuerte and the U.S. dollar.

Note 3.  Incorporation of Foreign Subsidiaries, page F-10

 3. We note that you accounted for your Venezuelan subsidiary as highly inflationary beginning
on January 1, 2010.  On page F-11, you state that  as a result of devaluation, you adjusted
your balance sheet and reduced shareholde rs’ equity of Ps. 3,700 million which was
accounted for at the time of the devaluation in  January 2010.  Please tell us if such amounts
were recognized through the in come statement or the cumulative translation adjustment and
how you determined this classification was appropriate. Please discuss the accounting
guidance you relied upon and tell us your consideration of disc losing your accounting
treatment.

We urge all persons who are responsible for th e 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 requir e.  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 responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 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 federa l securities laws of  the United States.

Hèctor Trevi ňo Gutièrrez
Coca-Cola FEMSA S.A.B. de C.V. August 19, 2011 Page 3

 You may contact Brian McAllister at (202)  551-3341 or Nasreen Mohammed at (202)
551-3773 if you have questions regarding comments  on the financial statements and related
matters.  Please contact me at ( 202) 551-3871 with any other questions.
 Sincerely,
   /s/ Brian K. Bhandari for
    Tia Jenkins         Senior Assistant Chief Accountant