SecProbe.io

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Mail Stop 3561
      October 12, 2005

Svante Carlsson
Chief Financial Officer
Stena AB
Masthuggskajen
SE-405 19 Gothenburg, Sweden

      RE:	Stena AB
    	Form 20-F for the Fiscal Year Ended December 31, 2004
    	File No. 033-99284

Dear Mr. Carlsson:

      We have reviewed your response letter dated September 14,
2005
and have the following comments.  Where indicated, we think you
should revise your document in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 20-F for the Fiscal Year Ended December 31, 2004

1. Refer to prior comment 3.  In future filings, please disclose
the
effect of this change in accounting estimate on income before
extraordinary items, net income and related per share amounts in
accordance with paragraph 33 of APB 20.

2. Refer to prior comment 4.  Please revise your disclosure in
Note 1
to clearly explain that the consolidation of two financial
investments relates to the investments qualifying as a variable
interest entity for US GAAP purposes.  In addition, explain that
under Swedish GAAP, these investments were previously accounted
for
under the cost method, but are now accounted for under equity
method
due to the implementation of a new accounting principal under
Swedish
GAAP.  Provide us with your intended disclosure.

Note 32 - Additional U.S. GAAP Disclosures, page F-51

3. Refer to prior comment 12.  We note that segment information
provided under Swedish GAAP does not provide appropriate
reconciliations to segment information under U.S. GAAP or all
information required under paragraphs 25-28 of FAS 131, such as
segment assets.  It is the staff`s position that U.S. GAAP segment
information should be provided for registrants electing to file
under
Item 18 of Form 20-F as the instructions to Item 18 indicates a
requirement to provide "all other information" required by U.S.
GAAP
as part of the reconciliation.  Please provide segment information
on
a U.S. GAAP basis in future filings.  For additional guidance on
items required for registrants electing to file under Item 18, you
may also refer to the SEC Staff Training Manual, Topic 6, IV(B).

* * * * *

      Please file your response to our comments via EDGAR within
fifteen business days from the date of this letter.  Please
understand that we may have additional comments after reviewing
your
response.  You may contact Cari Kerr at 202-551-3310 or Tracie
Northan at 202-551-3311.  You may also contact the undersigned at
202-551-3812 with any questions.

      Sincerely,

								Michael Fay
								Branch Chief

Via Fascimile: Svante Carlsson, Chief Financial Officer:  46-31-
12-
06-51

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Svante Carlsson
Stena AB
October 12, 2005
Page 1

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