SecProbe.io

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Mail Stop 0306

      March 18, 2005

Via U.S. Mail

Mr. James V. Gelly
Chief Financial Officer
777 East Wisconsin Avenue
Suite 1400
Milwaukee, Wisconsin 53202

	RE:	Rockwell Automation, Inc.
		Form 10-K for the fiscal year ended September 30, 2004
		File No. 1-12383

Dear Mr. Gelly:

     We have reviewed your filings and have the following comment.
We
have limited our review to those issues we have addressed in our
comment.  Please be as detailed as necessary in your explanation.
In
our comment, we 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
filings.
We look forward to working with you in these respects.  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 the fiscal year ended September 30, 2004

Consolidated Financial Statements - Page 30

Note 1, Basis of Presentation and Accounting Policies - Page 35

1. Please respond to the following comments regarding your revenue
recognition policy disclosure:
(A) We note your disclosure that revenue is "generally" recognized
when the requirements of SAB 104 have been met and that you
"generally" use certain means to determine the existence of an
arrangement.  The revenue recognition policy should be revised in
future filings to clearly indicate when this is not the case and
the
specific accounting treatment.
(B) Please tell us and disclose in future filings the nature and
significant terms of your customer returns, rebates and
incentives.
Explain the basis for your accounting and classification for each
and
cite the accounting literature upon which you relied. Include a
discussion of how you determine when to classify the rebate and
incentive in sales or cost of sales and why. Include a discussion
of
your balance sheet classification as well.
(C) Please provide us with a separate rollforward of your customer
returns, rebates and incentives for each period presented through
the
latest interim period. Include a separate column showing
adjustments
made in each period to the accruals. Clarify where you recorded
increases to the accrual in the statement of operations. If
material,
provide similar disclosure in future filings.
(D) Your disclosure indicates that changes to "other assumptions"
(other than historical experience) are used to estimate accruals
for
your rebates and incentives programs.  Please tell us and in
future
filings disclose the nature of the other assumptions used.
(E) We note from your business section (page 3) that your products
include software.  Please supplementally tell us your accounting
policies with regard to software and whether or not revenues from
software sales were material in any of the periods presented.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
cover letter with your response that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

      You may contact Heather Tress, Staff Accountant, at (202)
824-
5263 or me at (202) 942-2861 if you have questions regarding
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Daniel Gordon, Accounting Branch Chief, at
(202) 942-2813.

							Sincerely,

							Kate Tillan
							Reviewing Accountant
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Mr. James V. Gelly
Chief Financial Officer
Rockwell Automation, Inc.
March 18, 2005
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