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                                                               February 24, 2005

VIA FACSIMILE AND FEDEX
-----------------------

United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-0405
(202) 942-9528 (Fax)
Attention:        H. Roger Schwall
                  Gary Newberry
                  Shannon Buskirk

         Re:      MONSANTO COMPANY
                  Form 10-K, Filed November 3, 2004
                  Form 10-Q, Filed January 10,
                  2005 File No. 1-16167

Dear Messrs. Schwall and Newberry and Ms. Buskirk:

                  Reference is made to the Staff's letter, dated February 9,
2005, setting forth comments to the Report on Form 10-K for the year ended
August 31, 2004 (the "Form 10-K") and the Report on Form 10-Q for the quarter
ended November 30, 2004 (the "Form 10-Q") by Monsanto Company ("Monsanto" or the
"Company"). Set forth below are the Staff's comments, indicated in bold, and the
Company's responses. As discussed with the Staff on February 23, 2005, the
Company will incorporate changes to its filings prompted by the Staff's comments
on a going forward basis in all future filings, consistent with the responses
outlined below. We understand that the purpose of the Staff's review is to
assist the Company in its compliance with the applicable disclosure requirements
and to enhance the overall disclosure in its filings. As such, we understand
that the Staff may have further comments based on our responses.

                  In addition, we are providing in Schedules No. 1 and 2 hereto
supplemental information as requested in the Staff's comments, including our
responses to Comment number 5. We request that the Staff return all copies of
these Schedules, after its review is complete.

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Securities and Exchange Commission
February 24, 2005
page 2

      ACCOUNTING COMMENTS
      -------------------

      Form 10-K for the year ended August 31, 2004

      Item 7, Management's Discussion and Analysis of Financial Condition and
      -----------------------------------------------------------------------
      Results of Operations
      ---------------------

      Financial Measures, Page 24
      ---------------------------

1.       WE NOTE YOUR USE OF EBIT (EARNINGS BEFORE INTEREST AND TAXES) AS A
         MEASURE OF YOUR SEGMENTS' PROFIT, ITS DEFINITION AND THE RECONCILIATION
         TO NET INCOME IN NOTE 23 ON PAGE 112. WE NOTE YOUR CALCULATION OF EBIT
         EXCLUDES LOSSES FROM DISCONTINUED OPERATIONS, CUMULATIVE EFFECT OF
         ACCOUNTING CHANGES AND CUMULATIVE EFFECT OF CHANGE IN ACCOUNTING
         PRINCIPLES. IN THIS REGARD, IT APPEARS THE TITLE OF YOUR NON-GAAP
         MEASURE REQUIRES MODIFICATION AS IT DOES NOT CLEARLY IDENTIFY ALL
         ADJUSTMENTS YOU HAVE MADE TO THE WIDELY KNOWN AND RECOGNIZED MEASURE OF
         EBIT. THE REVISED TITLE OF YOUR NON-GAAP MEASURES SHOULD NOT REFER IN
         ANY WAY TO "EBIT" UNLESS THE MEASURE IS CALCULATED CONSISTENTLY WITH
         ITS READILY KNOWN DEFINITION. REFER TO QUESTION 14 OF THE FREQUENTLY
         ASKED QUESTIONS REGARDING THE USE OF NON-GAAP FINANCIAL MEASURES ISSUED
         ON JUNE 13, 2003 FOR FURTHER EXPLANATION.

                  RESPONSE. The first paragraph in the "Overview -- Financial
         Measures" section of Item 7 -- Management's Discussion and Analysis of
         Financial Condition and Results of Operations of Monsanto's Form 10-K,
         explains the usage of the term EBIT. This financial measure is used in
         the "Seeds and Genomics Segment" and "Agricultural Productivity
         Segment" sections of Management's Discussion and Analysis of Financial
         Condition and Results of Operations (MD&A) and in Note 23 to the
         consolidated financial statements.

                  The readily known definition defines EBIT as net income (loss)
         before interest and taxes. Monsanto also excludes discontinued
         operations and the cumulative effect of a change in accounting
         principle in its calculation. Throughout the Form 10-K, the Company
         defines EBIT as earning (loss) from continuing operations before
         cumulative effect of accounting change, interest and income taxes.
         Prospectively Monsanto will re-title its definition from "EBIT" to
         "Adjusted EBIT". In addition, Monsanto will prospectively add the
         following to the language that appears in MD&A and the segment
         footnote:

                  "EBIT is defined as net income (loss) before interest and
                  taxes. We have adjusted this definition to exclude two
                  additional items, discontinued operations and cumulative
                  effect of accounting change. We define "Adjusted EBIT" as net
                  income (loss) before interest, income taxes, discontinued
                  operations and cumulative effect of accounting change."

2.       WE NOTE YOUR DISCUSSION OF CHANGES IN THIS MEASURE ON A SEGMENT BASIS
         IN THE MANAGEMENT'S DISCUSSION AND ANALYSIS SECTION. THESE DISCUSSIONS
         SHOULD ALSO

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Securities and Exchange Commission
February 24, 2005
page 3

         INCLUDE A DESCRIPTION OF THE RECONCILING ITEMS THAT APPLY
         TO EACH PARTICULAR SEGMENT. PLEASE REFER TO QUESTION 19 OF THE
         FREQUENTLY ASKED QUESTIONS REGARDING THE USE OF NON-GAAP FINANCIAL
         MEASURES ISSUED ON JUNE 13, 2003, IF YOU REQUIRE FURTHER GUIDANCE. IN
         ORDER TO COMPLY WITH ITEM 10(E) OF REGULATION S-K, IT APPEARS YOUR
         DISCLOSURES SHOULD BE EXPANDED.

                  RESPONSE. In the "Seeds and Genomics Segment" and
         "Agricultural Productivity Segment" sections of MD&A, Monsanto includes
         financial results for Adjusted EBIT. Monsanto will prospectively modify
         the title and footnote to the charts to comply with its response to
         Comment number 1. Reconciling items between consolidated net income
         (loss) and "Adjusted EBIT" consist of interest, income taxes,
         discontinued operations and cumulative effect of a change in accounting
         principle. Prospectively Monsanto will revise footnote 2 to the Seeds
         and Genomics segment chart in MD&A as follows:

                  "We define "Adjusted EBIT" as net income (loss) before
                  interest, income taxes, discontinued operations and cumulative
                  effect of accounting change. Interest and income taxes are
                  recorded on a total company basis. We do not record these
                  items at the segment level. Discontinued operations relate
                  solely to the Seeds and Genomics segment and consist of the
                  European breeding and seed business for wheat and barley and
                  the plant-made pharmaceuticals program. See the "Results of
                  Operations" charts in MD&A and Note X -- Discontinued
                  Operations for detail of the "loss from operations of
                  discontinued businesses" for the periods presented. In the
                  transition period, the cumulative effect of a change in
                  accounting principle recorded was not related to this segment.
                  In calendar year 2002, we recorded a cumulative effect of a
                  change in accounting principle of $1,822 million, which was
                  solely related to the Seeds and Genomics segment (see Note X
                  -- Goodwill and Other Intangible Assets)."

                  Prospectively Monsanto will revise footnote 2 to the
         Agricultural Productivity segment chart in MD&A as follows:

                 "We define "Adjusted EBIT" as net income (loss) before
                  interest, income taxes, discontinued operations and cumulative
                  effect of accounting change. Interest and income taxes are
                  recorded on a total company basis. We do not record these
                  items at the segment level. There were no discontinued
                  operations related to this segment. In the transition period,
                  we recorded a cumulative effect of a change in accounting
                  principle of $12 million for the adoption of a new accounting
                  standard relating to asset retirement obligations, which was
                  solely related to the Agricultural Productivity segment. In
                  calendar year 2002, the cumulative effect of a change in
                  accounting principle recorded was not related to this
                  segment."

<PAGE>

Securities and Exchange Commission
February 24, 2005
page 4

      Item 8, Financial Statements and Supplementary Data
      ---------------------------------------------------

      Statement of Consolidated Operations, Page 63
      ---------------------------------------------

3.       WE NOTE YOU HAVE REPORTED THE $396 MILLION SOLUTIA PCB LITIGATION
         EXPENSE AS A SEPARATE OTHER EXPENSE IN THE YEAR ENDED AUGUST 31, 2003
         AND $58 MILLION RELATED TO THE SOLUTIA ASSUMED LIABILITIES AS OTHER
         EXPENSE - NET IN THE YEAR ENDED AUGUST 31, 2004. IT APPEARS THESE
         EXPENSES ARE RELATED TO PRIOR OPERATIONS. TELL US WHY EACH OF THESE
         ITEMS SHOULD BE CLASSIFIED AS A NON-OPERATING EXPENSE UNDER ARTICLE 5
         OF REGULATION S-X.

                  RESPONSE. Since Monsanto's business does not, and never did,
         include the operations of the Chemicals Business (defined below) for
         which the PCB litigation and Solutia's Assumed Liabilities relate,
         Monsanto believes the appropriate income statement line item to record
         these expenses was non-operating expense. The Company believes the $396
         million expense for the global settlement that Monsanto participated
         in, which included Solutia Inc. ("Solutia") and Pharmacia Corporation
         ("Pharmacia"), relating to certain Solutia PCB litigation in Alabama
         recorded in the eight-month transition period ended August 31, 2003,
         and the $58 million related to Solutia's Assumed Liabilities recorded
         in fiscal year 2004 were both properly recorded as non-operating
         expenses. Monsanto has incurred costs related to both matters pursuant
         to its obligation under the Separation Agreement (defined below) to
         indemnify Pharmacia. Monsanto's results of operations for all periods
         presented in the Form 10-K solely consist of the Ag Business (defined
         below). The Chemicals Business was separated from Pharmacia (then known
         as Monsanto Company) on September 1, 1997. On February 9, 2000,
         Monsanto was incorporated in Delaware as a wholly owned subsidiary of
         Pharmacia (then known as Monsanto Company) under the name "Monsanto Ag
         Company." Background of the relationships among Monsanto, Pharmacia,
         Pfizer Inc. ("Pfizer") and Solutia is provided in the following
         paragraphs.

                  BACKGROUND INFORMATION FOR THE ABOVE RESPONSE:

                  In the Form 10-K, the section "Relationships Among Monsanto
         Company, Pharmacia Corporation, Pfizer Inc. and Solutia Inc." in Part I
         -- Item 1 -- Business provides a brief background on the relationships
         among these corporations. Prior to September 1, 1997, a corporation
         that was then known as Monsanto Company ("Former Monsanto") operated an
         agricultural products business (the "Ag Business"), a pharmaceuticals
         business (the "Pharmaceuticals Business") and a chemical products
         business (the "Chemicals Business"). Former Monsanto is today known as
         Pharmacia. Pharmacia is now a wholly owned subsidiary of Pfizer, which
         together with its subsidiaries operates the Pharmaceuticals Business.
         Monsanto's business consists of the operations, assets and liabilities
         that were previously the Ag Business. Solutia comprises the operations,
         assets and liabilities that were previously the Chemicals Business.

                  On September 1, 1997, Pharmacia (then known as Monsanto
         Company) entered into a Distribution Agreement ("Distribution
         Agreement") with Solutia related to the

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Securities and Exchange Commission
February 24, 2005
page 5

               transfer of the operations, assets and liabilities of the
          Chemical Business from Pharmacia to Solutia. Pursuant to the
          Distribution Agreement, Solutia assumed and agreed to indemnify
          Pharmacia (then known as Monsanto Company) for certain liabilities
          related to the Chemicals Business. On September 1, 2000, Monsanto
          entered into a Separation Agreement (Separation Agreement) with
          Pharmacia related to the transfer of the operations, assets and
          liabilities of the Ag Business from Pharmacia to us. Pursuant to the
          Separation Agreement, Monsanto was required to indemnify Pharmacia for
          any liabilities primarily related to the Ag Business or the Chemicals
          Business, and for liabilities assumed by Solutia pursuant to the
          Distribution Agreement, to the extent that Solutia fails to pay,
          perform or discharge those liabilities. On December 17, 2003, Solutia
          and 14 of its U.S. subsidiaries filed a voluntary petition for
          reorganization under Chapter 11 of the U.S. Bankruptcy Code.

4.       WE NOTE YOUR LINE ITEM TITLED "AMORTIZATION AND ADJUSTMENTS OF
         GOODWILL" ON THE STATEMENT OF OPERATIONS AND THE $69 MILLION IMPAIRMENT
         OF GOODWILL RECORDED DURING THE YEAR ENDED AUGUST 31, 2004. AS THIS
         AMOUNT RELATES TO THE IMPAIRMENT OF PREVIOUSLY RECORDED GOODWILL, WE
         BELIEVE IT IS NOT APPROPRIATE TO CHARACTERIZE THIS AMOUNT AS AN
         "ADJUSTMENT" TO GOODWILL. IN ADDITION, THE DEPICTION OF THIS AMOUNT AS
         AN ADJUSTMENT DOES NOT TRULY DESCRIBE THE NATURE OF THIS AMOUNT AS
         "ADJUSTMENT TO GOODWILL" COULD HAVE SEVERAL MEANINGS. WE NOTE YOU HAVE
         DESCRIBED THIS AMOUNT IN NOTE 9 ON PAGE 84 AS AN IMPAIRMENT AND BELIEVE
         THE REMAINING DISCLOSURES THROUGHOUT YOUR FILING REQUIRE MODIFICATION
         TO CONSISTENTLY LABEL THE $69 MILLION AS AN IMPAIRMENT.

                  RESPONSE. Although Monsanto has historically used the title
         "Amortization and adjustments of goodwill" on the Statement of
         Consolidated Operations to include goodwill impairment losses, Monsanto
         will change this title to "Impairment of goodwill" in future filings.
         Since the Statement of Consolidated Operations for the year ended
         December 31, 2001 (the last year for which Monsanto amortized
         goodwill), will not be included in future filings, the reference to
         amortization is no longer necessary. Related disclosures in future
         filings will also be modified to consistently label the $69 million and
         future impairments, if any, as goodwill impairment losses.

      Statement of Consolidated Financial Position, page 64
      -----------------------------------------------------

5.       WE NOTE THE REPORTED AMOUNT OF OTHER ASSETS AND MISCELLANEOUS
         SHORT-TERM ACCRUALS ARE GREATER THAT 5% OF REPORTED TOTAL ASSETS AND
         TOTAL CURRENT LIABILITIES, RESPECTIVELY. ON A SUPPLEMENTAL BASIS, TELL
         US THE COMPONENTS OF THESE ITEMS. DISCLOSURE OF CERTAIN ITEMS MAY BE
         REQUIRED UNDER ITEM 5.02 OF REGULATION S-X.

                  RESPONSE. Monsanto supplementally advises the Staff as
         follows:

                  OTHER ASSETS

                  See attached supplemental Schedule No. 1 to this re