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  OPEN JOINT STOCK COMPANY

  «WIMM-BILL-DANN FOODS»

  16/15, Yauzsky Bul., Moscow, 109028, RUSSIA

  Tel.: +7 (095) 733 9726, 733 9727, Fax: +7 (095) 733 9725

August 26,
2005

VIA EDGAR

Mr. William
Choi

Branch
Chief

Division
of Corporation Finance

U.
S. Securities and Exchange Commission

Mail
Stop 3561

Washington,
D.C. 20549

United
States of America

Re:               Wimm-Bill-Dann Foods OJSC (the “Company”)

Form 20-F for the fiscal year ended December 31, 2004 (the “Form 20-F”)

Filed June 30, 2005

File No. 1-31232

Response to comment letter dated August 11, 2005 (received by a fax
dated August 12, 2005)

Dear
Mr. Choi:

This letter responds to the
comments of the Staff of the U.S. Securities and Exchange Commission (the “Commission”)
on the Form 20-F set forth in the Staff’s letter dated August 11,
2005. To facilitate your review, we have set forth below each of your comments
with our corresponding response and have numbered the items to correspond to
your original letter. In our responses, we indicate how we intend to revise our
disclosure in future filings in response to these comments.

Cover
Page

1.              Our records show your File Number is 1-31232,
rather than file number 333-14278 that appears on the cover pages of your
Forms 20-F and 6-K. In future filings, please include the correct file number.

Response

We
confirm that we will use the correct file number in future filings.

Consolidated Financial
Statements, page F-1

Consolidated
Statements of Income and Comprehensive Income, page F-5

2.              We note that you have presented earnings per
share data for income from currency translation adjustment and comprehensive
income. It appears that these are non-GAAP financial measures, which are
prohibited by Item 10(c)(1)(ii)(C) of Regulation S-K. Per share data other
than that relating to net income should not be presented on the face of your
consolidated statements of income and comprehensive income. Please tell us your
basis in GAAP with reference to the authoritative guidance you are applying. If
you are unable to cite specific authoritative guidance supporting your
presentation, please remove the non-GAAP earnings per share data in future
filings.

Response

We agree with the Staff’s comment that the
presentation of earnings per share data for income from currency translation
adjustment and comprehensive income on the face of the 2001 – 2004 consolidated
statement of income and comprehensive income is a non-GAAP financial measure. Such
presentation will be deleted from future filings.

Notes
to Consolidated Financial Statements, page F-8

Note 3: Summary of Significant Accounting
Policies, page F-8

3.              You disclose on page 71 that the
Toshkent Sut Dairy plant is not consolidated in your financial results. Please
tell why you do not control the Toshkent Sut Dairy plant given your majority
ownership. Please refer to ARB 51 as amended by FAS 94. Please also tell us the
amount of your investment in the Toshkent Sut Dairy plant. Finally, tell us
whether you account for your investment in the Toshkent Sut Dairy plant using
the cost method or equity method of accounting and your basis for doing so.
Please refer to APB 18.

Response

We acquired a 77% interest
in Toshkent Sut Dairy Plant (“Toshkent Sut”) from a third party in April 2004
for 6.9 million rubles (approximately $250,000) in cash. Toshkent Sut is a
joint stock company registered in the Republic of Uzbekistan and located in
Tashkent. The acquisition was made as a first step in a series of contemplated
transactions aimed at our entering the Uzbek market. At December 31, 2004,
our internal commitment towards funding on-going expansion in Uzbekistan was
also contingent upon obtaining certain tax and other economic incentives from
the Uzbek government which were ultimately awarded in early 2005.

At the time we prepared and reported
our 2004 consolidated financial statements, reliable US GAAP financial
information for Toshkent Sut was not readily available. Rather than delay the
reporting of our 2004 consolidated results, we recorded the amounts paid as an
advance related to property, plant and equipment as we believed that this
accounting was materially appropriate. The following table summarizes our
estimate of the un-audited summary financial information of this legal entity at
December 31, 2004 and for the year then ended:

  Financial Statement Item

  Amount, thousand US

  dollars

  As a percentage to our

  consolidated balance sheet or

  income statement item

  Total assets

  $

  992

  0.12

  %

  Total liabilities

  1,285

  0.32

  %

  Equity

  (292

  )

  (0.08

  )%

  Sales

  113

  0.01

  %

  Net loss

  258

  1.12

  %

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We believe that the above
amounts are clearly immaterial to our financial position and results of
operations in 2004. In 2005, we have initiated re-organizational activities in
Uzbekistan. Toshkent Sut is scheduled for liquidation in 2006 and our on-going
operations in Uzbekistan will be through a newly established legal entity. We
intend to consolidate our Uzbekistan operations in our 2005 results.

* * * *

In connection with our
responses above, we acknowledge that

•                  the
Company is responsible for the adequacy and accuracy of the disclosure in the Form 20-F;

•                  Staff
comments or changes to disclosure in response to Staff comments do not
foreclose the Commission from taking any action with respect to the Form 20-F;
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.

We appreciate your comments
and believe that the above explanations respond to your questions. Please do
not hesitate to contact us should you have any questions or require any
clarifications relating to the responses above.

  Sincerely,

  /s/ Dmitry A. Anisimov

  Dmitry A. Anisimov

  Chief Financial
  Officer

  Copies to:

  Scott Ruggiero

  Bill Thompson

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