SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      August 8, 2005

Via U.S. Mail

Alan L. Boeckmann
Chief Executive Officer
Fluor Corporation
One Enterprise Drive
Aliso Viejo, California 92656

RE:		Fluor Corporation
      Form 10-K for the fiscal year ended December 31, 2004
      Response letter dated May 3, 2005
		File No. 1-16129

Dear Mr. Boeckmann:

      We have reviewed the above filing and response letter and
have
the following comment.  Our review with respect to this issue does
not preclude further review by the Assistant Director group with
respect to other issues.  At this juncture, we are asking you to
provide us with supplemental information, so that we may better
understand your disclosure.  Please be as detailed as necessary in
your response. 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.

10-K for fiscal year ended December 31, 2004

General -

We note your May 3, 2005, response to our comment letter dated
March
29, 2005, and the clear distinction you make between Fluor and its
subsidiaries in your response.  Please confirm for us that Fluor
Iran
and FD Eurasia are the only Fluor subsidiaries that have any
contact
with Iran.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      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 comment, 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 filings; 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.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Pamela Long
		Assistant Director
		Division of Corporation Finance

</TEXT>
</DOCUMENT>