SecProbe.io

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Mail Stop 6010

      		November 18, 2005

VIA U.S. Mail and Facsimile (817) 551-4700

Jacqualyn A. Fouse
Chief Financial Officer
Alcon, Inc.
Bosch 69
6331 Hunenberg, Switzerland

Re:	Alcon, Inc.
	Form 20-F for the year ended December 31, 2004
	Filed March 15, 2005
	Form 6-K filed October 20, 2005
	File No. 001-31269

Dear Ms. Fouse:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments. Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
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 information so we may better understand
your
disclosure.  After reviewing this information, we may 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 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.

Form 20-F for the year ended December 31, 2004

Item 15. Controls and Procedures, page 92

1. In future filings, please revise your disclosure concerning
changes in internal control over financial reporting to disclose
any
change in your internal control over financial reporting that
occurred during the last fiscal quarter that has materially
affected,
or that is reasonably likely to materially affect, your internal
control over financial reporting, consistent with the language of
amended Item 308(c) of Regulation S-K.

Consolidated Financial Statements

(1) Summary of Significant Accounting Policies and Practices, page
F-
7

(m) Revenue Recognition, page F-9

2. Refer to your disclosure on page 39 stating that you "sell
lasers
and other surgical equipment used to perform laser refractive
surgeries, and in the United States, charge a technology fee for
each
surgery performed."  Please clarify in future filings and in your
response how your revenue recognition policy for laser and other
surgical equipment differs among customers, channels, products and
geographical location. In addition, clarify the nature and
accounting
treatment for the technology fee charged for sales in the United
States and whether this is in addition to the sales price of the
equipment. The accounting treatment for your equipment that is
used
by customers to perform laser surgeries should also be disclosed.
3. As a related matter, tell us and disclose in future filings how
you determine the number of procedures performed in order to
recognize revenue for technology fees.
4. We note that you have customer incentive programs, including
discounts and rebates. Explain to us the specifics of these
incentive
programs, for example the classification of and accounting for
these
sales incentives.  Tell us how these incentives are estimated at
the
time of shipment.  Revise future filings to clarify.  Refer to
EITF
01-9 in your response, as applicable.

Form 6-K filed October 20, 2005

Condensed Consolidated Financial Statements (unaudited)

(13) Contingencies, page 13

5. We see that a jury rendered a verdict against the company for
$94.8 million on May 6, 2005 related to patent infringement
litigation.  Tell us and disclose in future filings how you
considered the criteria in paragraph 8 of SFAS 5 in determining
whether you should record an estimated loss from the litigation.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

	 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 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.

      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.

	You may contact Kristin Lochhead at (202) 551-3664 or me at
(202) 551-3676 if you have questions.  In this regard, please do
not
hesitate to contact Martin James at (202) 551-3671 with any other
questions.

      Sincerely,

Brian Cascio
      Accounting Branch Chief

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Ms. Fouse
Alcon, Inc.
November 18, 2005
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