SecProbe.io

October 7, 2011
 Via E-Mail

Hèctor Trevi ňo Gutièrrez
Chief Financial Officer Coca-Cola FEMSA S.A.B. 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 the Fiscal Year Ended December 31, 2010
Filed June 17, 2011 Correspondence submitted September 15, 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.
            Item 5. Operating and Financial Review Prospects, page 40

 Consolidated Results of Operati ons by Reportable Segment, page 49

1. We note your response to prior comment one on the exchange rates and devaluation.  You
state that 2010 exchange rate was 4.30 boliv ars per U.S. dollar (which equated to 2.87
bolivars per Mexican peso) and the 2009 exchange rate of 2.15 bolivars per U.S. dollar (which equated to 6.07 bolivars per Mexican pe so).  Please explain how you computed the
equated bolivar per Mexican peso rates.  Pleas e further clarify which rates were used to
translate the financial statements of your Venezu elan subsidiary to the reporting currency, the
Mexican peso.

Hèctor Trevi ňo Gutièrrez
Coca-Cola FEMSA S.A.B. de C.V. October 7, 2011 Page 2

 2. We note your response to prior comment one a nd your discussion of Venezuelan operations
on page 49 stating revenues declined by 37.4% in  2010 principally due to the devaluation of
the Venezuelan bolivar.  Please provide a more  expansive discussion and analysis on results
of operations and clarify the amount of the dec line attributable to currency devaluation and
differentiate the trends attribut able to core operating results.  Please provide us with proposed
disclosure that you plan to include in future filings.

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.
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/Tia Jenkins

    Tia Jenkins

Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Mining