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Siemens AG, Corporate Finance, 80312 Munich, Germany

Ms. Cecilia D. Blye

Chief

Office of Global Security Risk

Division of Corporation Finance

U.S. Securities and Exchange Commission

450 Fifth Street, N.W., Mail Stop 5546

Washington, D.C. 20549-5546, USA

October 19, 2005

    Re:

    Siemens Aktiengesellschaft

Form 20-F for the Fiscal Year Ended September 30, 2004

Filed November 29, 2004

File No. 001-15147

Dear Ms. Blye:

     We are writing in response to your letter dated September 12, 2005 setting out two comments on
our above-referenced Report on Form 20-F. For ease of reference, we have repeated the Staff’s
comments in italicized text prior to our responses.

    Comment

    1.

    We note addresses and contact information for Siemens in Tehran, Damascus and Khartoum
(see http://worldwide.med.siemens.com). We also note a Business Week article in which a Siemens
spokesman responds to an inquiry about operations in Sudan by saying that the company has
“very limited business, mainly focused on infrastructure and medical products” (see
“Hitting Sudan in the Pocketbook, Pension funds are taking notice of a growing push to cut
ties to the rogue state” Business Week (May 2, 2005)).

    In light of this information, and the fact that Iran, Sudan and Syria are identified as
state sponsors of terrorism by the U.S. State Department, and are subject to economic
sanctions administered by the Treasury Department’s Office of Foreign Assets Control,
please describe for us the extent of your current and planned operations in, or contacts
with, Iran, Sudan and Syria, including through distributors, foreign subsidiaries and
other arrangements, whether direct or indirect. With a view to disclosure, please
address the materiality of any such operations, contracts or arrangements and your view
as to whether those operations or arrangements constitute a material investment risk for
your security holders.

    In preparing your response please consider that evaluations of materiality should not be
based solely on quantitative factors, but should also include consideration of
qualitative factors that a reasonable investor would deem important in making an
investment decision, including the potential impact of corporate
activities upon a company’s reputation and share
value. In this regard, we note the Business Week article referenced above also states
that “[s]ome U.S. funds are turning up the heat. Last October, Edward Smith, chairman of
the Illinois

    Siemens AG

Corporate Finance

Head: Heinz-Joachim Neubürger

    Postal address:

Siemens AG

Corporate Finance

80312 Muenchen

    Office address:

Wittelsbacherplatz 2

80333 Muenchen

Tel: +49 (89) 636-00

Fax: +49 (89) 636-34404

Siemens Aktiengesellschaft: Chairman of the Supervisory Board: Heinrich v. Pierer; Managing Board: Klaus Kleinfeld, Chairman, President
and Chief Executive Officer; Johannes Feldmayer, Thomas Ganswindt, Edward G. Krubasik, Rudi Lamprecht, Heinz-Joachim Neubürger,
Jürgen Radomski, Erich R. Reinhardt, Uriel J. Sharef, Claus Weyrich, Klaus Wucherer

Registered offices: Berlin and Munich, Commercial registries: Berlin Charlottenburg, HRB 12300, Munich, HRB 6684

Page 1 of 6

    investment board, sent letters to top officials at Siemens warning of growing pressure
from U.S. investors.” We note also that legislation requiring divestment from, or
reporting of interests in, companies that do business with U.S.-designated state sponsors of
terrorism has been adopted by Arizona and Louisiana; and legislation requiring divestment
from, or reporting of interests in, companies that do business with Sudan recently has
been proposed by several other U.S. states, and adopted by Illinois, Oregon and New
Jersey.

    Response to Comment

         As described in more detail below, Siemens does not consider its interests in and
dealings with Iran, Sudan and Syria, either individually or in the aggregate, as
constituting a material investment risk for its security holders, notwithstanding the
fact that Iran, Sudan and Syria are included in the U.S. State Department’s list of state
sponsors of terrorism. We have considered both quantitative and qualitative factors in
reaching this conclusion.

         Siemens Aktiengesellschaft is a stock corporation organized in the Federal Republic
of Germany. At the end of fiscal 2004 (September 30, 2004), the Siemens consolidated
group had around 430,000 employees worldwide and did business in approximately 190
countries. We had total consolidated sales for fiscal 2004 of EUR 75,167 million. We
offer a wide variety of products and services in the fields of information and
communications, automation and control, power, transportation, medicine, lighting, and
financing and real estate.

         As your reference to our website suggests, it is a matter of open record that we
engage in business in Iran, Sudan and Syria, among many other countries. Relative to the
size of the Siemens group, however, our activities over the periods covered by our 20-F
Report in each of these three countries were small, as explained more fully below. We
actively employ systems and procedures designed to keep our group in compliance with
applicable export control programs, including those of the United States, Germany and the
European Union.

         Materiality Standard

         In May 2001, then-Acting SEC Chairman Laura Unger noted in a publicly available
letter that “the Supreme Court has held that information is material if a reasonable
investor would be substantially likely to consider the information significant in making
an investment decision.” In addition, a May 8, 2001 memorandum from David Martin, then
Director of the SEC’s Division of Corporation Finance, accompanying Acting Chairman
Unger’s letter, stated that “[i]n assessing materiality, the SEC staff takes the view
that the reasonable investor generally focuses on matters that have affected, or will
affect, a company’s profitability or financial outlook” and that “[i]f it is reasonably
likely that U.S. governmental sanctions will be imposed on the company as a result of its
operations in a particular country, the risk would need to be disclosed if the sanctions
were likely to have a material impact on the company.” We note that the webpage for the
Office of Global Security Risk on the Commission’s website states that the Commission is
“committed to maintaining the materiality standard as the basis for our disclosure-based
approach.”

         As explained below, employing this standard, Siemens believes that its activities
with regard to Iran, Sudan and Syria do not represent, either individually or in
aggregate, a material investment risk for its security holders.

         Quantitative Considerations

         Iran

         We have been engaged in business in Iran since 1865. At present, we have direct or
indirect majority ownership interests in four Iranian subsidiaries, and minority
ownership interests (all 20% or less holdings) in three Iranian companies. Each of our
subsidiaries in Iran is engaged in one or more of our fields of business (principally,
 public power generation and transmission, public telecommunications and public
transportation). At the end of fiscal 2004, the Siemens consolidated group had 277
permanent employees in Iran—less than .07% of our global consolidated group total.
Siemens’ sales from Iran in fiscal 2004 amounted to approximately EUR 287 million, or
less than 0.4% of total consolidated sales.1

    1

    In this letter, “Sales” are
calculated with regard to the location of the customer (rather than the
location of the selling company). “Employee” with respect to a
country generally excludes persons working for Siemens there on a transient or
project basis.

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         Siemens’ group sales and employee levels in Iran are increasing from this
comparatively small base, in keeping with the overall development of the Iranian economy
and with the acceleration of growth in public infrastructure projects resulting from
increased government spending. Our July 2005 acquisition of the Austrian engineering
group VA Technologie AG (VA Tech), which operates in the businesses of power generation
and transmission, metallurgy and infrastructure, also will contribute to our Iranian
sales growth. The implementation of Siemens export control standards at VA Tech is
already in process.

         Sudan

         Since 2003, we have maintained in Sudan a representative office with three permanent
employees.

         Our activities in Sudan are very limited, and are focused on public infrastructure
development (particularly public telecommunications, public power generation and
transmission) and medical products. Siemens’ sales from Sudan for fiscal 2004 amounted
to approximately EUR 12 million, or less than .02% of total consolidated sales. This was
lower than the level of around EUR 25 million in the prior two years. At present,
Siemens does not intend to significantly expand its business in Sudan.

         Syria

         Siemens has a representative office in Syria that is managed by an agent. Siemens
has no employees permanently stationed in Syria. Our activities in Syria are focused on
public telecommunications and other public infrastructure projects. Siemens’ sales from
Syria in fiscal 2004 were approximately EUR 56 million, or less than .08% of the
consolidated figure.

         We believe that, as the data above indicate, on a quantitative basis, our activities
with regard to Iran, Sudan and Syria do not represent, either individually or in
aggregate, a material investment risk for security holders. In fiscal 2004, our
aggregate sales from all three countries amounted to less than 0.5% of our total sales,
and our employee headcount in those three countries amounted to less than 0.1% of our
total. Accordingly, we believe that, from a quantitative perspective, a reasonable
investor would not consider our activities in these three countries to pose a material
investment risk.

         Non-Quantitative Considerations

         On the basis of non-quantitative factors, including principally the impact of our
activities in Iran, Sudan and Syria on share value and reputation, Siemens does not
believe that those activities pose a material investment risk for our security holders.
In fact, we believe that investors in the shares of a non-U.S. company headquartered in
Europe with a long history of international dealings (140 years in the case of Iran) and
extensive involvement in public infrastructure development, such as ours, would
anticipate that we engage in some business activities in Iran, Sudan and Syria,
particularly considering that our website identifies offices or contact persons in those
countries and we do not otherwise make a secret of our activities there. We have no
reason to conclude that our existing shareholders or potential new investors, taken as a
whole, consider our involvement in these three countries as a factor that affects our
reputation or share value adversely.

         We respectfully submit that having business activities in Iran, Sudan and Syria is
not uncommon among many of our peer competitors in several of our fields of business, and
so very likely represents the norm rather than the exception for that group, at least
insofar as non-U.S. companies are concerned. Because of the structure of the domestic
economies of these three countries, where the private sector is nascent or marginal and
where public infrastructure has developed significantly, it is also not uncommon for
governmental agencies or government-controlled businesses to be transaction counterparts.

         We believe that, with regard to Iran, Sudan and Syria, our compliance systems are
sufficient to make remote the risks of a violation of U.S., German or European Union
economic sanctions or export control laws that would create a material investment risk
for our security holders. More specifically, with regard to the U.S. sanctions and
export control laws administered by the U.S. Office of Foreign Asset Control (OFAC):

         Iran. The U.S. sanctions against Iran that are administered by OFAC are
inapplicable to a non-U.S. company such as Siemens, other than with regard to (i) its
U.S. subsidiaries and U.S. nationals and

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    permanent resident aliens, (ii) the export of goods or services between the United States
and Iran and (iii) the re-exportation of U.S.-origin goods and technology. To the best
of our knowledge, our U.S. subsidiaries and our employees who are U.S. nationals or
permanent resident aliens are not involved in any of our activities in Iran. Siemens
does not export goods or services from the United States to Iran or vice versa.
Furthermore, we are convinced that we have adequate controls and procedures in place so
that the likelihood of our violating the U.S. re-exportation restrictions is remote.

         Sudan. We do not believe that the range of OFAC-administered sanctions against
Sudan has application to our activities there. Among other things, to the best of our
knowledge, our U.S. subsidiaries are not involved in activities at which those U.S.
sanctions are directed, and our employees who are U.S. nationals or permanent resident
aliens are uninvolved in our Sudan activities.

         Syria. In view of the nature of the U.S. sanctions applied to Syria to date,
consisting primarily of bars on the exportation or re-exportation of most U.S. goods
(other than food and medicine), certain transportation restrictions and the blocking of
certain property and property interests in the United States or within the control of
U.S. persons, as well as the limited scope of our activities in Syria and the operation of
our internal compliance system, we are convinced that the risk that our activities in
Syria would expose us to financial or reputational harm on the basis of these sanctions
is remote.

         Since the commencement of our activities in Iran, Sudan and Syria, we have made a
considerable number of contacts in these countries in the ordinary course of business.
We do not believe that the existence of any of these contacts represents material
information for investors in our securities.

         In summary, notwithstanding that Iran, Sudan and Syria have been identified as state
sponsors of terrorism by the U.S. Department of State and are, to varying degrees,
subject to economic sanctions administered by the OFAC, we do not believe that our
activities in those three countries constitute a material investment risk for Siemens’
security holders, taking both quantitative and non-quantitative factors into account.

    Comment

    2.

    Please describe for us whether any of your equipment or technology used or sold in or
to countries identified as state sponsors of terrorism has a military purpose or, to the
best of your knowledge, understanding and belief, can be put to a military use. In this
regard, we note Congressional testimony that lithotripters sold to Iraq by Siemens use “the
same high-precision switch that triggers a nuclear weapon.” (Testimony of Gary Milhollin
Before the Senate Committee on Governmental Affairs
http://hsgac.senate.gov/052600_milhollin.pdf (May 26, 2000)).

    Response to Comment

         The Staff’s comment is challenging for us to respond to, since many items (even
those with no apparent military application) can be put to use by military personnel. We
can best respond by describing our control systems and procedures related to exports of
military products and services (and products that have been
designated as having a dual-use) to customers in the six designated state sponsors of terrorism. When we refer here
to military and dual-use products and services, we mean products or services identified
as such on one of the export lists published by relevant German, E.U. or U.S.
authorities.

    At present, among other things