SecProbe.io

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

Mail Stop 3651

								July 14, 2005

 BY U.S. Mail and Facsimile [ (403) 205 - 9000 ]

 Mr. Robert J. Ritchie, President and Chief Executive Officer
 CANADIAN PACIFIC RAILWAY LIMITED
 CANADIAN PACIFIC RAILWAY COMPANY
Suite 500, Gulf Canada Square
401-9th Avenue S.W.
Calgary, Alberta, Canada  T2P 4Z4

 	Re:	Canadian Pacific Railway Limited
 		Form 40-F for Fiscal Year Ended December 31, 2004
 		Filed March 7, 2005
 		File No. 1-01342

 	Re:	Canadian Pacific Railway Company
 		Form 40-F for Fiscal Year Ended December 31, 2004
 		Filed March 7, 2005
 		File No. 1-15272

Dear Mr. Ritchie:

	We have reviewed the above referenced filings based upon an
examination restricted solely to considerations of Selected
Financial
Data, Management`s Discussion and Analysis, and the Financial
Statements and have the following comments.  Where indicated, we
think you should revise your documents in response to these
comments
in future filings with us.  Please confirm that such comments will
be
complied with.  If you disagree, we will consider your explanation
as
to why our comments are inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing the information, we may or may not raise additional
comments.

	Pursuant to Rule 101(a)(3) of Regulation S-T, your response
should be submitted in electronic form, under the label "corresp,"
within 15 business days of the date of this letter.

	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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Robert J. Ritchie
Canadian Pacific Railway Limited
Canadian Pacific Railway Company
July 14, 2005
Page 2

FORM 40-F (Fiscal Year Ended December 31, 2004)

2004 Annual Information Form

Network and Right of Way, page 14

1. We note from disclosure in Note 23 to the Canadian GAAP audited
financial statements that you operate in only one business
segment,
rail transportation, and that the financial information presented
at
this level is used by management for decision making.  However,
given
that your network is composed of four primary corridors, the
Western,
the Southern, the Central, and the Eastern corridors, tell us how
you
have determined that operations generated in these corridors do
not
result in separate and distinct reportable business segments.
Please
note that specific geographic areas can represent reportable
segments.  Your response should address paragraphs 10-15 of SFAS
No.
131.  If you have aggregated the corridors, tell us how the
aggregation criteria under paragraph 17 of SFAS No. 131 had been
met.
Further, clarify for us if the information used by the chief
operating decision maker to assess company performance and
allocate
resources is based on financial information at the consolidated
financial level, with no analysis given to lower levels or units
of
operations, as implied in Note 23 to the audited financial
statements.  We may have additional comments after review of your
response.

Other

	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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 the disclosures they have made.

	In connection with responding to our comments, 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 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.

Robert J. Ritchie
Canadian Pacific Railway Limited
Canadian Pacific Railway Company
July 14, 2005
Page 3

	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 filing or in
response to our comments on your filing.

Closing

      You may contact Ms. Beverly A. Singleton, Staff Accountant,
at
(202) 551-3328, or Ms. Margery Reich, Senior Staff Accountant, at
(202) 551-3347 if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
551-3211 with any other questions.

      Sincerely,

							David R. Humphrey
							Accounting Branch Chief

??

??

??

??

</TEXT>
</DOCUMENT>