SecProbe.io

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							April 20, 2005

via facsimile and U.S. mail

Mr. John F. Inserra
Chief Financial Officer
c/o Del Monte Fresh Produce Company
241 Sevilla Avenue
Coral Gables, FL  33134

	Re:	Fresh Del Monte Produce Inc.
		Form 20-F, Filed March 8, 2005
		Form 20-F/A, Filed March 9, 2005
		File No. 333-07708

Dear Mr. Inserra:

      We have reviewed the above filings and have the following
comments.  We have limited our review to the areas commented on
below.  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 on 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 year ended December 31, 2004

General

1. We note the several references in the 20-F to your operations
in
the Middle East and Africa.  We note also the disclosure on p.26
that
one of your wholly-owned subsidiaries is Del Monte Fresh Produce
(Korea) Ltd., incorporated in Korea.  Please identify for us the
Middle Eastern and African countries in which you have operations.
If any of these operations are in a country identified by the U.S.
State Department as a state sponsor of terrorism, or if you have
other contacts with any such country, identify each such country
for
us.  Advise us also whether your Korean subsidiary is in North
Korea,
a country identified by the U.S. State Department as a state
sponsor
of terrorism.

If any of your operations or other contacts is with a country
identified as a state sponsor of terrorism, please advise us of
the
materiality of those contacts to the Company, and give us your
view
as to whether those contacts constitute a material investment risk
for your security holders.  If you have contacts with more than
one
such country, provide the requested information with respect to
your
contacts with the countries individually and in the aggregate.  In
preparing your response, please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of all factors, including the
potential
impact of corporate activities upon a company`s reputation and
share
value, that a reasonable investor would deem important in making
an
investment decision.

Controls and Procedures, page 72

2. We note your disclosure that your "Chief Executive Officer and
Chief Financial Officer concluded that as of December 31, 2004,
[your] disclosure controls and procedures are effective in
providing
reasonable assurance that information relating to [you] that is
required to be included in [your] periodic filings with the SEC is
recorded, processed, summarized and reported as and when
required."
Revise to clarify, if true, that your officers concluded that your
disclosure controls and procedures are also effective to ensure
that
information required to be disclosed in the reports that you file
or
submit under the Exchange Act is accumulated and communicated to
your
management, including your chief executive officer and chief
financial officer, to allow timely decisions regarding required
disclosure.  Refer to Exchange Act Rule 13a-15(e).

Closing Comments

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
You may wish to provide us with marked copies of your disclosure
revisions to expedite our review.  Please furnish a cover letter
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.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the company`s disclosure, they
are responsible for the accuracy and adequacy of the disclosures
they
have made.  In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

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
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Regina Balderas, Staff Accountant, at (202)
942-7768 or, in her absence, Jill Davis, Branch Chief, at (202)
942-
1996 if you have questions regarding comments on the financial
statements and related matters.  Direct questions relating to all
other disclosure issues to the undersigned at (202) 942-1870.
Direct
all correspondence to the following ZIP code:  20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director

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Fresh Del Monte Produce Inc.
April 20, 2005
page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

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