SecProbe.io

August 15, 2013

Via E -Mail
Javier Astaburuaga Sanjines
Chief Financial  Officer
Mexican Economic Development, Inc.
Colonia Bella Vista
Monterrey, NL 64410
Mexico

Re: Mexican Economic Development, Inc.
 Form 20-F for the Year Ended December 31, 2012
Filed April 8, 2013
File No. 333 -08752

Dear Mr. Sanjines :

We have reviewed your filing an d have the following comments. Please comply with the
following comments in future filings.  Confirm in writing that you will do so and explain to us
how you intend to comply.  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 providing the requested
information or  by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you pro vide in response to these  comments, we may
have  additional comments

Form 20 -F for the Year Ended December 31, 2012

Consolidated  Financial Statements

Consolidated Statements of Cash Flows, page F -6
1. We note you have used “ Income before income taxes an d share of the profit of associates
and joint ventures accounted for using the equity method” as your starting point to
determine cash flows from operating activities. We believe that profit and loss, as defined
in IAS 1, is what IAS 7 intended to use to m easure cash flows from operating activities .
Please tell us why you believe your presentation is in accordance with IAS 7.

Javier Astaburuaga Sanjines
Mexican Economic Development, Inc.
 August 15, 2013
 Page 2

 Notes to the consolidated financial statements
2 Basis of presentation
2.2.1 Presentation of consolidated income statement, page F -7
2. Since you present costs and expenses by function,  please provide additional information
about the expenses by nature in accordance with paragraph 104 of IAS 1.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 t he disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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  federal securities laws of the United States.

You may contact Blaise Rhodes , Staff Accountant,  at (202) 551-3774 or Ivette Leon ,
Assistant Chief Accountant,  at (202) 551-3351  if you have questions regarding comments on the
financial statements and re lated matters.

Sincerely,

/s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining