SecProbe.io

CORRESP
 1
 filename1.htm

 August 12, 2025

 VIA EDGAR TRANSMISSION

 Office of Manufacturing

 Attn: Mindy Hooker and Kevin Stertzel

 Division of Corporation Finance

 U.S. Securities & Exchange Commission

 100 F Street NE

 Washington, DC

 Re: Mexican Economic Development, Inc.

 Form 20-F for Fiscal Year Ended December 31,
2024

 Filed April 24, 2025

 File No. 001-35934

 Dear Ms. Hooker and Mr. Stertzel,

 This letter addresses the comment made by the staff
(the " Staff ") of the Securities and Exchange Commission (the " Commission ") as set forth in a letter
dated July 21, 2025, regarding the above-referenced Annual Report on Form 20-F for the fiscal year ended December 31, 2024 (the " Annual
Report ") of Fomento Económico Mexicano, S.A.B de C.V. ( Mexican Economic Development, Inc. ) (" FEMSA ").

 We have reproduced the Staff's comment below in bold and provided
our response immediately below.

 Form 20-F for the Fiscal Year Ended December 31, 2024

 Risk Factors

 Risks Related to Our Company, page 4

 1. We note your disclosure at the bottom of page 8 regarding risks linked to international cartels and transnational criminal organizations
present in jurisdictions that you have operations. We further note media sources indicate your OXXO operations in Nuevo Laredo, Mexico
were temporarily closed in 2024 due to cartel related concerns. In future filings, please revise your disclosure to expand on the risks
related to heightened criminal activity in Mexico. Your revised disclosure should address, but not be limited to, how criminal activity
affects companies and employees through extortion, theft, kidnapping, and violence. If material, include impacts such as, lost income
and associated costs due to store closures, increased insurance and security costs, theft, and extortion losses. Also, consider discussing
how corruption and ties between criminal organizations and authorities may affect your operations and how cartels may attempt to control
the sale, distribution, and pricing of goods. Please provide us with your draft disclosure enhancements in your response.

 We respectfully acknowledge the Staff's
comment.

 To date, the activities of criminal organizations present
in territories where we have operations, which may include international cartels and international criminal organizations, have not resulted
in an interruption to the operations of FEMSA and its subsidiaries or otherwise resulted in losses that would be material to its business,
financial condition or results of operations.

 FEMSA and its subsidiaries have experienced two non-material
incidents in recent periods. With respect to the operations in Nuevo Laredo, Mexico referenced by the Staff, the temporary closure affected
stores and gas stations which constitute less than 1% of our total points of sale, for a period of approximately nine days, which represented
less than .1% of the sales in Mexico for 2024. FEMSA's subsidiary Coca-Cola FEMSA also paused certain operations in Puente de Ixlta,
Morelos, Mexico from September 2024 to November 2024 after four employees were kidnapped. This affected one distribution center, which
constituted less than 1% of Coca-Cola's distribution centers in Mexico, and such closure represented less than 1% of the sales in
Mexico for 2024. FEMSA confirms that it will disclose impacts in future filings if material to its business, financial condition or results
of operations, including due to store or other location closures, increased insurance and security costs, theft, and extortion losses.
FEMSA collaborates with federal and local governmental authorities to combat and limit the impact of criminal organizations.

 FEMSA will also expand the cited disclosure in the risk factor
section in future filings on Form 20-F to be more specific with respect to the risks associated with the presence of criminal organizations
in the territories in which FEMSA and its subsidiaries operate. For example, as of the date hereof, we would expect to include the additional
disclosures below in future filings (new language bolded and underlined ):

 We operate in multiple territories and are subject to complex
regulatory frameworks with increased enforcement activities with respect to anti-corruption, anti-bribery, anti-money laundering, water,
environment, energy, labor, criminal, taxation, health and antitrust. In addition, on February 20, 2025, the U.S. government designated
certain international cartels and transnational criminal organizations as Foreign Terrorist Organizations ("FTOs"), several
of which are known to be present in jurisdictions where we have operations. These designations expand the tools available for U.S. authorities
to prosecute members of FTOs or individuals or entities alleged to have provided them "material support" and increase the
risk of potential criminal and civil liability against such entities or individuals. We maintain a Global Integrity Compliance Program
that is supervised by our senior management and employ a Legal Compliance Officer in each of our business units. Reports on such compliance
program are presented to the Audit Committee of our Board of Directors on an annual basis. Despite our internal governance and compliance
processes, including due diligence processes of third parties, we may be subject to breaches by our employees, contractors or other agents
of our code of ethics, anti-corruption and anti-money laundering policies, other internal policies, or applicable laws or regulations,
including instances of fraudulent behavior, corrupt practices, improper payments and dishonesty by any of them. In particular, the
activities of criminal organizations, including international cartels and transnational criminal organizations, present in territories
in which we operate have resulted in and in the future may result in impacts on our business, disruptions to our operations, and the temporary
closure of stores. We also could be required to cease operations in certain territories, or we may experience material income losses,
increase in safety-related and insurance expenses, loss of product and revenue, or health and safety risks to our employees. While we
cooperate with law enforcement authorities in these territories, and despite government efforts to combat public corruption, these efforts
may not be sufficient to prevent or avoid local, state and federal authorities and our employees being subject to corrupt practices or
threats of violence which could lead to potential disruptions of our operations. We also cannot foreclose the possibility of criminal
organizations affecting our operations by attempting to control the sale, distribution, and pricing of certain goods.

 . . .

 Our failure to comply with applicable laws and other standards
could harm our reputation, subject us to substantial fines, sanctions or penalties and adversely affect our business. There is no assurance
that we will be able to comply with changes in any laws and regulations within the timelines established by the relevant regulatory authorities.
 In addition, criminal activity targeted towards us and our employees, including by international cartels and transnational criminal
organizations, could materially adversely affect our business, financial condition or results of operations, including through sustained
interruption of our business, decreased revenues, and higher expenses.

 While the above language is provided as an example, our actual
disclosure in future filings will depend on our material risks at the time of such disclosure.

 * * *

 Thank you for your consideration of our response. If you have any questions
or require any additional information with respect to the above, please do not hesitate to contact FEMSA or Duane McLaughlin (+1-212-225-2106)
of our U.S. counsel Cleary Gottlieb Steen & Hamilton LLP.

 Sincerely,

 By:
 /s/ Alejandro Gil Ortiz

 Alejandro Gil Ortiz General Counsel

 Mexican Economic Development, Inc. (Registrant)

 cc.: Duane McLaughlin

 Cleary Gottlieb Steen & Hamilton LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 12, 2025

Alejandro Gil Ortiz
General Counsel
Mexican Economic Development Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, NL 64410 Mexico

 Re: Mexican Economic Development Inc.
 Form 20-F for the Fiscal Year Ended December 31, 2024
 File No. 001-35934
Dear Alejandro Gil Ortiz:

 We have completed our review of your filing. We remind you that the
company and
its management are responsible for the accuracy and adequacy of their
disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of Corporation
Finance
 Office of Manufacturing
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 21, 2025

Alejandro Gil Ortiz
General Counsel
Mexican Economic Development Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, NL 64410 Mexico

 Re: Mexican Economic Development Inc.
 Form 20-F for the Fiscal Year Ended December 31, 2024
 Filed April 24, 2025
 File No. 001-35934
Dear Alejandro Gil Ortiz:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Fiscal Year Ended December 31, 2024
Risk Factors
Risks Related to Our Company, page 4

1. We note your disclosure at the bottom of page 8 regarding risks linked
to international
 cartels and transnational criminal organizations present in
jurisdictions that you have
 operations. We further note media sources indicate your OXXO operations
in Nuevo
 Laredo, Mexico were temporarily closed in 2024 due to cartel related
concerns. In
 future filings, please revise your disclosure to expand on the risks
related to
 heightened criminal activity in Mexico. Your revised disclosure should
address, but
 not be limited to, how criminal activity affects companies and employees
through
 extortion, theft, kidnapping, and violence. If material, include impacts
such as, lost
 income and associated costs due to store closures, increased insurance
and security
 costs, theft, and extortion losses. Also, consider discussing how
corruption and ties
 between criminal organizations and authorities may affect your
operations and how
 July 21, 2025
Page 2

 cartels may attempt to control the sale, distribution, and pricing of
goods. Please
 provide us with your draft disclosure enhancements in your response.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Mindy Hooker at 202-551-3732 or Kevin Stertzel at
202-551-3723
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
December 13, 2023
Alejandro Ortiz
General Counsel
Mexican Economic Development, Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, Nuevo León 64410, México
Re:Mexican Economic Development, Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 24, 2023
File No. 001-35934
Dear Alejandro Ortiz:
            We have completed our review of your filing. We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

August 10, 2023

VIA EDGAR TRANSMISSION

Office of Manufacturing

Attn: Dale Welcome and Kevin Stertzel

Division of Corporation Finance

U.S. Securities & Exchange Commission

100 F Street NE

Washington, DC

 Re: Mexican Economic Development, Inc.

Form 20-F for Fiscal Year Ended December 31,
2022

Filed April 24, 2023

File No. 33-99720

Dear Mr. Welcome and Mr. Stertzel,

This letter addresses the comments made by the staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”) as set forth in a letter
dated July 17, 2023, regarding the above-referenced Annual Report on Form 20-F for the fiscal year ended December 31, 2022 (the “Annual
Report”) of Fomento Económico Mexicano, S.A.B de C.V. (Mexican Economic Development, Inc.) (“FEMSA”).

We have reproduced the Staff’s comment below in bold and provided
our response immediately below.

Form 20-F for the Year Ended December 31, 2022

Financial Statements

Note 3.18. Intangible Assets, page F-33

 1. We note your accounting policy and disclosures regarding your treatment of TCCC bottling agreement
intangible assets as indefinite lived intangible assets even though they have a stated term of 10 years and contain a 10 year renewal
right. We also note your policy may be inconsistent with other entities with similar assets. Please refer to paragraph 94 of IAS 38 and
more fully explain to us why you believe your accounting policy is appropriate and consistent with IFRS, given the stated term of the
agreements. In addition, please explain to us the process and expected costs of renewing the agreements at the end of their 10 year term
and how you concluded renewals are essentially perpetual in nature.

We respectfully acknowledge the Staff’s
comment. In response, we detail below the reasoning behind the accounting policy regarding indefinite lived intangible assets.

Bottler agreements are the standard
agreements that The Coca-Cola Company (“TCCC”) enters into with bottlers in each territory. Pursuant to the bottler
agreements, our subsidiary Coca-Cola FEMSA, S.A.B. de C.V. (“KOF”) is authorized to manufacture, sell and distribute
Coca-Cola trademark beverages within specific geographic areas. These bottler agreements are automatically renewable for ten-year
terms, subject to the right of either party to give prior notice that it does not wish to renew a specific agreement.

The bottler agreements are extended
for successive ten-year terms in perpetuity unless the following conditions and procedures are complied with: eighteen months prior to
the expiration of any ten-year period, either party may elect for any reason, with or without cause, to give notice to the other of its
preliminary intention not to renew the agreement. Said notice, however, will not be binding until a final notice of non-renewal is given
six months thereafter by either party. During the six-month period between preliminary notice and possible final notice of non-renewal,
the parties may reconsider and nonetheless mutually agree in writing to renew the agreement for a further ten-year period. In the event
that the decision is not to renew, the bottler agreement will terminate and expire at the end of any such ten-year term. These provisions
are included in Article 7 / Section 27 of the bottler agreement filed as Exhibit 4.4 to KOF’s annual report on Form 20-F filed on
April 14, 2023 (file No. 1-12260).

The bottler agreements are treated as
indefinite-lived intangible assets because we have determined they are perpetual in nature and will continue to be renewed at each expiration
date, in accordance with the automatic renewal consideration described in Article 7 / Section 27 of the bottler agreement mentioned above.
This is supported by the following factors:

 · Bottler agreements are automatically renewable for ten-year terms at no cost, subject to the non-renewal
procedures described above.

 · The renewal process described above does not require any action. Only the non-renewal requires an action.

 · TCCC has not expressed at any time during our relationship any intention not to renew any bottler agreement.

 · KOF has been producing and distributing soft drinks in Mexico since 1979 and since that time has entered
into bottler agreements with TCCC in other countries in Latin America.

    2

 · KOF has no plans to stop producing or distributing Coca-Cola trademark beverages in the territories.

 · TCCC’s substantial and long-term equity ownership interest in KOF since 1993. TCCC currently owns 27.8%
of KOF’s capital stock and 32.9% of its voting shares.

 · The substantial cost and disruption that would be experienced by TCCC if the agreements were terminated,
and the loss of any future economic benefits expected to flow to both TCCC and KOF from renewal of the agreements.

Our analysis of all of the factors discussed
above has led us to conclude that the assets have indefinite lives because there is no foreseeable limit to the period over which the
assets are expected to generate net cash flows for us, as provided for in paragraph 88 of IAS 38.

We believe that our accounting policy
is also consistent with paragraph 94 of IAS 38. Even though that paragraph states that “The useful life of an intangible asset that
arises from contractual or other legal rights shall not exceed the period of the contractual or other legal rights…”. It
also establishes that for contractual rights that are conveyed for a limited term that can be renewed “…the useful life of
the intangible asset shall include the renewal period(s) only if there is evidence to support renewal by the entity without significant
cost.” As there is no cost associated with renewal, we believe the unlimited renewal periods are appropriately included pursuant
to paragraph 94.

*	       *	       *

    3

Thank you for your consideration of our response. If you have any questions
or require any additional information with respect to the above, please do not hesitate to contact FEMSA or Duane McLaughlin (+1-212-225-2106)
of our U.S. counsel Cleary Gottlieb Steen & Hamilton LLP.

    Sincerely,

    By:
    /s/ Alejandro Gil Ortiz

    Alejandro Gil Ortiz

    General Counsel

    Mexican Economic Development, Inc.

    (Registrant)

 cc.: Duane McLaughlin

Cleary Gottlieb Steen & Hamilton LLP

    4

United States securities and exchange commission logo
July 17, 2023
Alejandro Ortiz
General Counsel
Mexican Economic Development, Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, Nuevo León 64410, México
Re:Mexican Economic Development, Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 24, 2023
File No. 001-35934
Dear Alejandro Ortiz:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Financial Statements
Note 3.18 Intangible Assets, page F-33
1.We note your accounting policy and disclosures regarding your treatment of TCCC
bottling agreement intangible assets as indefinite lived intangible assets even though they
have a stated term of 10 years and contain a 10 year renewal right.  We also note your
policy may be inconsistent with other entities with similar assets.  Please refer
to paragraph 94 of IAS 38 and more fully explain to us why you believe your accounting
policy is appropriate and consistent with IFRS, given the stated term of the agreements.
In addition, please explain to us the process and expected costs of renewing
the agreements at the end of their 10 year term and how you concluded renewals are
essentially perpetual in nature.

 FirstName LastNameAlejandro Ortiz
 Comapany NameMexican Economic Development, Inc.
 July 17, 2023 Page 2
 FirstName LastName
Alejandro Ortiz
Mexican Economic Development, Inc.
July 17, 2023
Page 2
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Dale Welcome at 202-551-3865 or Kevin Stertzel at 202-551-3723 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

July 28, 2015

Via E -mail
Daniel Alberto Rodriguez Cofré
Chief Financial Officer
Mexican Economic Development, Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, NL 64410 Mexico

Re: Mexican Economic Development, Inc.
 Form 20-F for the Year Ended December 31, 2014
Filed April 21, 2015
File No. 001 -35934

Dear Mr. Cofré :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person u nder the
federal securities laws of the United States.  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 the
information the Securities Exchange Act of 1934 and all  applicable rules require.

Sincerely,

 /s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining

CORRESP
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filename1.htm

Fomento Económico Mexicano, S.A.B. de C.V.

Ave. General Anaya 601 Pte., Col. Bella Vista

64410 Monterrey, N.L. Mexico

July 20, 2015

VIA EDGAR TRANSMISSION

Ms. Tia L. Jenkins

Senior Assistant Chief Accountant

Office of Beverages, Apparel, and Mining

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Mexican Economic Development, Inc.

Form 20-F for the Year Ended December 31, 2014

Filed April 21, 2015

File No. 001-35934

Dear Ms. Jenkins:

By letter dated July
6, 2015 (the “Comment Letter”), the Securities and Exchange Commission (the “SEC”) provided comments on
the annual report on Form 20-F for the fiscal year ended December 31, 2014, as filed on April 21, 2015 by Fomento Económico
Mexicano, S.A.B. de C.V. (the “Company”). We submit today herewith, via EDGAR transmission, responses to the SEC’s
comments.

For your convenience, we
have reproduced the SEC’s comments in bold below and have provided the Company’s responses immediately below each comment.

Form 20-F for the Year Ended December
31, 2014

Audited Consolidated Financial Statements
of Fomento Economico Mexicano, S.A.B. de C.V.

Note 10. Investments in Associates and
Joint Ventures, page F-43

 1. We note from the disclosure included on page F-44 and elsewhere
in your filing that from the date of your acquisition of a 51% investment in CCFPI through December 31, 2014, the results of CCFPI
have been recognized by Coca-Cola FEMSA using the equity method of accounting. We also note that your use of the equity method
is based on the following factors: (i) during the initial four-year period from the acquisition date, some relevant activities
require joint approval between Coca-Cola FEMSA and The Coca-Cola Company; and (ii) the potential voting rights to acquire the remaining
49% of CCFPI provided by the put right obtained in the acquisition are not probable to be executed in the foreseeable future due
to the fact that the call option is out of the money at both December 31, 2014 and 2013. Please tell us and revise the notes to
your financial statements in future

    Ms. Tia Jenkins, page 2

filings to explain in further
detail the nature of the activities that require joint approval between Coca-Cola FEMSA and The Coca-Cola Company during the initial
four-year period following your acquisition of the 51% interest in this entity. Also, please explain in further detail why you
believe the joint approval of these activities results in a lack of control over CCFPI and the resultant need for consolidation
of this entity pursuant to IFRS 10, when it appears that you have majority voting control over this entity as a result of your
51% interest. Please provide your proposed disclosures as part of your response.

In response to the
SEC’s comments, below please find the reasons why we used the equity method to recognize the effects on financial position
and comprehensive income of CCFPI and our proposed disclosure for future filings:

 (i)      CCFPI’s board of directors consists of four members appointed by Coca-Cola FEMSA and three
members appointed by The Coca-Cola Company. For the approval of certain decisions including those related with the organic growth
of the business of CCFPI, CCFPI requires the approval of the majority of its board of directors, including the affirmative vote
of at least one of The Coca-Cola Company’s directors, which effectively gives The Coca-Cola Company a veto power over these
decisions. These decisions relate to, among other things, CCFPI’s ability to pay dividends, to issue or redeem capital stock,
to enter into certain agreements, or to change the nature of its business. In addition, joint approval of both Coca-Cola FEMSA
and The Coca-Cola Company is currently required for the approval of CCFPI’s annual business plan, which is the key document
pursuant to which CCFPI’s business is operated and which includes, among others: (a) main commercial and operating strategies,
such as capital expenditures and incurrence of debt, (b) the annual budget and (c) investment plans.[1]

 (ii)      Taking into consideration (a) the definition of ‘control’ established in IFRS 10 paragraph
7, which states that an investor controls an investee if and only if the investor has all of the following characteristics: (1)
power over the investee, (2) exposure or rights to variable returns from its involvement with the investee, and (3) the ability
to use its power over the investee to affect the amount of the investor’s returns; and (b) that the relevant activities mentioned
in (i) above are consistent with an example of relevant activities necessary to have power over an investee stated in IFRS 10.B.12
(which specifically includes the establishment of operating and capital budgets), we believe that we do not have control over CCFPI,
notwithstanding our voting interest, since we do not unilaterally have the power to direct the relevant activities that are important
to the operation and control of CCFPI’s business and the return on investment for both Coca-Cola FEMSA and The Coca-Cola
Company, without the joint approval of The Coca-Cola Company.

 (iii)      In future filings we will clarify our disclosure to make reference to this relevant activity so
that a reader of our consolidated financial statements may understand the reason why Coca-Cola FEMSA uses the equity method to
recognize the effects on financial position and comprehensive income of CCFPI, as follows: “Although Coca-Cola FEMSA currently
owns 51% of CCFPI, when considering (i) the terms of the shareholders

1
See Section 4.1. of the shareholders agreement dated as of January 25,2013 by and among Coca-Cola FEMSA and The Coca-Cola Company
incorporated by reference to Exhibit 4.27 of Coca-Cola FEMSA’s Annual Report on Form 20-F filed on March 15, 2013.

    Ms. Tia Jenkins, page 3

agreements (specifically the
joint approval of both Coca-Cola FEMSA and The Coca-Cola Company required to approve CCFPI’s annual business plan, which
is the key document pursuant to which CCFPI’s business is operated); and (ii) potential voting rights to acquire the remaining
49% of CCFPI are not probable to be executed in the foreseeable future if the call option remains “out of the money”,
we conclude that Coca-Cola FEMSA did not control CCFPI during any of the periods presented in our consolidated financial statements.”

Note 12. Intangible Assets, page F-50

Sensitivity to Changes
in Assumptions, page F-54

 2. We note from your disclosure on page F-54 that Coca-Cola FEMSA
performed an additional impairment sensitivity calculation, taking into account an adverse change in post-tax change in Weighted
Average Cost of Capital, according to the country risk premium, using for each country the relative standard deviation between
equity and sovereign bonds and an additional sensitivity to the volume of 100 basis points, except for Costa Rica, and concluded
that no impairment would be recorded. Please explain why Costa Rica was excluded from the additional sensitivity analysis using
100 basis points consistent with the other countries and indicate whether an impairment charge with respect to Costa Rica’s
goodwill and distribution rights would have been required had its indefinite-lived intangible assets been subject to the 100-basis-point
sensitivity analysis used for the other countries.

In response to
the SEC’s comments, the following discussion explains why the 100-basis-point sensitivity analysis was not applied to Costa
Rica:

Coca-Cola FEMSA’s
Costa Rican subsidiary was included in the sensitivity analysis using 60-basis-points because Costa Rica, unlike other markets,
has been implementing a lower pricing strategy to foster growth in per-capita consumption. This strategy, while improving affordability
has been negatively affecting profitability in absolute terms and will continue to do so in the short term. Therefore, we decided
to perform the 60-basis-point sensitivity analysis given this lower pricing strategy in order to avoid affecting the results misleadingly.
If we had performed the sensitivity analysis using 100-basis-points in Costa Rica, it would have resulted in an impact on the value
of the sensitivity; however, Coca-Cola FEMSA’s Costa Rican subsidiary would have continued passing the impairment test with
1.5x.

Note 23. Earnings per Share, page F-88

 3. Please tell us and revise Note 23 to clearly explain how net
income attributable to the controlling interest is allocated between the Series B and Series D shares for purposes of your earnings
per share computations. Please provide your proposed disclosures as part of your response.

Ms. Tia Jenkins, page 4

In response to the
Staff’s comment, the following discussion explains how net income attributable to the controlling interest is allocated between
Series “B” and Series “D” shares for purposes of our earnings per share computations:

Net income
attributable to the controlling interest is allocated by computing an allocation of earnings percentage based on the weighted average
amount of shares outstanding at the end of the year (see Note 22.1); and considering the dividend rights granted to each of series
“B” or “D”. The non-cumulative premium dividend to be paid to series “B” shareholders will
be 100% and to series “D” shareholders will be 125% of any dividend paid to series “B” shareholders.

    Series “B”
    Series “D”

    Shares outstanding
    9,246.42
    8,644.71

    Dividend rights per series
    100%
    125%

    Shares outstanding, as adjusted to reflect dividend rights
    9,246.42
    10,805.89

    Allocation of earnings, weighted
    46.11%
    53.89%

The following
would be the form of our disclosure (adding 2015 and removing 2012) in the next filing on Form 20-F as part of our Notes
to the Consolidated Financial Statements for the year ended December 31, 2015 and including similar disclosure for prior periods
presented:

    2014

    2013
    2012

    Per Series “B” Shares
    Per Series “D” Shares

    Per Series “B” Shares
    Per Series “D” Shares
    Per Series “B” Shares
    Per Series “D” Shares

    Shares expressed in millions:

    Weighted average number of shares for basic earnings per share
    9,240.54
    8,621.18

    9,238.69
    8,613.80
    9,237.49
    8,609.00

    Effect of dilution associated with non-vested shares for share based payment plans
    5.88
    23.53

    7.73
    30.91
    8.93
    35.71

    Weighted average number of shares adjusted for the effect of dilution (Shares outstanding)
    9,246.42
    8,644.71

    9,246.42
    8,644.71
    9,246.42
    8,644.71

        Dividend rights per series

        (see note 22.1)

    100%
    125%

    100%
    125%
    100%
    125%

    Weighted average number of shares further adjusted to reflect dividend rights
    9,246.42
    10,805.89

    9,246.42
    10,805.89
    9,246.42
    10,805.89

    Allocation of earnings, weighted
    46.11%
    53.89%

    46.11%
    53.89%
    46.11%
    53.89%

    Net Controlling Interest Income Allocated
    $  7,701.08
    $  8,999.92

    $  7,341.74
    $  8,579.98
    $  9,548.21
    $  11,158.58

********

    Ms. Tia Jenkins, page 5

Also, as requested
by the Staff, the Company acknowledges that:

§
it is responsible for the adequacy and accuracy of the disclosure in its filings;

§
Staff comments or changes to disclosure in response to Staff comments do not foreclose the SEC 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 SEC or any person under the federal
securities laws of the United States.

Thank you for
your consideration of the Company’s response. If you or any other member of the Staff has any further questions or comments
concerning the response, or if you require additional information, please do not hesitate to contact Duane McLaughlin at Cleary
Gottlieb Steen & Hamilton LLP at (212) 225-2000.

Very truly
yours,

           	/s/ Daniel
Alberto Rodríguez Cofré

Mr. Daniel Alberto Rodríguez
Cofré

Chief Financial Officer

Fomento Económico Mexicano, S.A.B.
de C.V.

cc:

Carlos Eduardo Aldrete Ancira

Fomento Económico Mexicano,
S.A.B. de C.V.

Duane McLaughlin

Cleary Gottlieb Steen & Hamilton LLP

July 6, 2015

Via E -mail
Daniel Alberto Rodriguez Cofré
Chief Financial Officer
Mexican Economic Development, Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, NL 64410 Mexico

Re: Mexican Economic Development, Inc.
 Form 20-F for the Year Ended December 31, 2014
Filed April 21, 2015
File No. 001 -35934

Dear Mr. Cofré :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not bel ieve our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.

Form 20 -F for the Year Ended December 31, 2014

Audited Consolid ated Financial Statements of Fomento Economico Mexicano, S .A.B. de C.V
Notes to the Co nsolidated Financial Statements , page F -7
Note 10. Investments in Associates and Joint Ventures, page F -43

1. We note from the disclosure included on page F -44 and elsewhere in your filing that from
the date of your acquisition of a 51% investment in CCFPI through De cember 31, 2014,
the results of CCFPI have been recognized by Coca -Cola FEMSA using the equity
method of accounting. We also note that your use of the equity method is based on the
following factors: (i) during the initial four -year period from the acquisi tion date, some
relevant activities require joint approval between Coca -Cola FEMSA and The Coca -Cola
Company; and (ii) the potential voting rights to acquire the remaining 49% of CCFPI
provided by the put right obtained in the acquisition are not probable to be executed in
the foreseeable  future due to the fact that the call option is out of the money at both

Daniel Alberto Rodriguez Cofré
Mexican Economic Development, Inc.
July 6, 2015
Page 2

 December 31, 2014 and 2013. Please tell us and revise the notes to your financial
statements in future filings to explain in further detail the nature  of the activities that
require joint approval between Coca -Cola FEMSA and The Coca -Cola Company during
the initial four -year period following your acquisition of the 51% interest in this entity.
Also, please explain in further detail why you believe the j oint approval of these activities
results in a lack of control over CCFPI and the resultant need for consolidation of this
entity pursuant to IFRS 10, when it appears that you have majority voting control over
this entity as a result of your 51% interest.  Please provide your proposed disclosures as
part of your response.

Note 12. Intangible Assets, page F -50
Sensitivity to Changes in Assumptions, page F -54

2. We note from your disclosure on page F -54 that Coca -Cola FEMSA performed an
additional impairment s ensitivity calculation, taking into account an adverse change in
post-tax change in Weighte d Average Cost of Cap ital, according to the country risk
premium, using for each country the relative standard deviation between equity and
sovereign bonds and an additional sensitivity to the volume of 100 basis points, except
for Costa Rica, and concluded that no impairment would be recorded. Please explain why
Costa Rica was excluded from the additional sensitivity analysis using 100 basis points
consistent with the other countries and indica te whether an impairment charge with
respect to Costa Rica’s goodwill and distribution rights would have been required had its
indefinite -lived intangible assets been subject to the 100 -basis -point sensitivity analysis
used for the other countries.

Note 2 3. Earnings per S hare, page F -88

3. Please tell us and revise Note 23 to clearly explain how net income attributable to the
controlling interest is allocated between the Series B and Series D shares for purposes of
your earnings per share computations. Please provide your proposed disclosures as part
of your response.

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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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.

Daniel Alberto Rodriguez Cofré
Mexican Economic Development, Inc.
July 6, 2015
Page 3

 In respon ding to our comments, please provide  a written 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 State s.

You may contact Suying Li  at (202) 551 -3335 or Linda Cvrkel at (202) 551 -3813 if you
have questions regarding comments on the financial statements and related matters.

Sincerely,

 /s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining

July 2, 2014

Via E -mail
Javier Astaburuaga Sanjines
Chief Financial Officer
Mexican Economic Development, Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, NL 64410 Mexico

Re: Mexican Economic Development, Inc.
 Form 20-F for the Year Ended December 31, 2013
Filed April 16, 2014
File No. 001 -35934

Dear Mr. Sanjines :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person u nder the
federal securities laws of the United States.  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 the
information the Securities Exchange Act of 1934 and all  applicable rules require.

Sincerely,

 /s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining

CORRESP
1
filename1.htm

Fomento Económico Mexicano, S.A.B. de C.V.

Ave. General Anaya 601 Pte., Col. Bella Vista

64410 Monterrey, N.L. Mexico

June 23, 2014

VIA FACSIMILE AND EDGAR TRANSMISSION

Ms. Tia L. Jenkins

Senior Assistant Chief Accountant

Office of Beverages, Apparel, and Mining

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Mexican Economic Development, Inc.

Form 20-F for the Fiscal Year Ended December 31, 2013

Filed April 16, 2014

(File No. 001-35934)

Dear Ms. Jenkins:

By letter dated June
10, 2014 (the “Comment Letter”), the staff (the “Staff”) of the Securities and Exchange Commission (the
“SEC”) provided a comment on the annual report on Form 20-F for the fiscal year ended December 31, 2013, as filed on
April 16, 2014 (the “2013 Form 20-F”) by Fomento Económico Mexicano, S.A.B. de C.V. (the “Company”).
We today submit herewith, via facsimile and EDGAR, a response to the Staff’s comment.

For your convenience, we have reproduced below
the Staff’s comment in bold and have provided the Company’s response immediately below the comment.

Form 20-F for the Year Ended December 31, 2013

Item 5. Operating and Financial Review and Prospects

Liquidity and Capital Resources, page 72

Please provide us with, and confirm that you will include in future filings, a more detailed analysis
of the components of the statements of cash flows (i.e., operating, investing, and financing activities) that explains the significant
year-to-year variations in each line item (e.g. explain the significant change in receivables, inventories etc.) for each period
presented. In this regard, please ensure to include robust discussions describing and quantifying the specific effect of the significant
causal factors that contributed to the material changes in your operating, investing and financing cash flows. Refer to Item 5
of Form 20-F and SEC Release No. 33-8350 as it relates to liquidity and capital resources for further guidance.

Ms. Tia Jenkins, page 2

In response to the Staff’s comment
the following discussion provides a more detailed analysis of the components of the statements of cash flows for each period presented.
In addition, pursuant to the Staff’s request, the Company will, in its next filing on Form 20-F for the year ended
December 31, 2014 include a similar disclosure covering all periods presented. We will add this similar disclosure after our
presentation of the Principle Sources and Uses of Cash table in the Liquidity and Capital Resources section.

The following is a summary of the principal
sources and uses of cash for the years ended December 31, 2013, 2012 and 2011, from our consolidated statement of cash flows:

Principal Sources and Uses of Cash

Years ended December 31, 2013, 2012 and 2011

(in millions of Mexican pesos)

    2013
    2012
    2011

    Net cash flows provided by operating activities
      Ps. 28,758
      Ps.	30,785
      Ps.	21,247

    Net cash flows used in investing activities
      (55,231 )
      (14,643 )
      (18,089 )

    Net cash flows provided by (used in) financing activities
      20,584
      (3,418 )
      (6,258 )

    Dividends paid
      (16,493 )
      (9,186 )
      (6,625 )

Our principal source of liquidity has
generally been cash generated from our operations, however we have obtained financing from financial institutions to fund the acquisition
of investments based on our growth strategy. We have traditionally been able to rely on cash generated from operations because
a significant majority of the sales of Coca-Cola FEMSA and FEMSA Comercio are on a cash or short-term credit basis, and OXXO stores
are able to finance a significant portion of their initial and ongoing inventories with supplier credit. In our opinion, our working
capital is sufficient for our present requirements. Our principal use of cash has generally been for capital expenditure programs,
debt repayment and dividend payments. In the last 3 years, Coca-Cola FEMSA has devoted a significant part of its cash to acquire
bottling operations as part of its investment strategy and during 2013, FEMSA Comercio entered into two new markets through the
acquisition of two drugstore businesses and one quick service restaurant chain.

Our net cash generated by operating activities
was Ps. 28,758 million for the year ended December 31, 2013 compared to Ps. 30,785 million for the year ended December 31, 2012,
a decrease of Ps. 2,027 million or 7%.  This decrease was primarily the result of lower financing from suppliers in the amount
of Ps. 3,316 million as well as higher amounts of income taxes paid of Ps. 934 million because of higher levels of taxable income,
and increased accounts receivable of Ps. 1,202 million. This was partially offset by an increase of Ps. 2,900 in our cash flow
from operating activities before changes in operating accounts due to our increased sales on a cash basis.

Our net cash used in investing activities
was Ps. 55,231 million for the year ended December 31, 2013 compared to Ps. 14,643 million for the year ended December 31, 2012,
an increase of Ps. 40,588 million or 277%.  This increase was primarily due to the acquisition of Grupo Yoli for Ps. 1,046
million, Companhia Fluminense de Refrigerantes for Ps. 4,648 million, Spaipa S.A. Industria Brasileira de Bebidas for Ps. 23,056
million, other acquisitions of Ps. 3,021 million and an investment in shares of Coca-Cola Bottlers Philippines for Ps. 8,904 million
in 2013.

Ms. Tia Jenkins, page 3

Our net cash generated by financing activities
was Ps. 20,584 million for the year ended December 31, 2013 compared to net cash used in financing activities of Ps. 3,418 million
for the year ended December 31, 2012, an increase of Ps. 24,002 million or 702%. This increase was primarily due to higher proceeds
from bank borrowings in 2013 of Ps. 78,907 million as compared to Ps. 14,048 million in 2012, offset by higher amounts of payments
on bank loans of Ps. 39,962 million in 2013 as compared to Ps. 5,872 million in 2012 as well as higher dividend payments of Ps.
16,493 million in 2013 compared to Ps. 9,186 million in 2012. Cash generated by financing activities was primarily used to finance
our business acquisitions.

Our net cash generated by operating activities
was Ps. 30,785 million for the year ended December 31, 2012 compared to Ps. 21,247 million for the year ended December 31, 2011,
an increase of Ps. 9,538 million or 45%.  This increase was primarily the result of an increase of Ps. 6,565 million in our
cash flow from operating activities before changes in operating accounts due to our increased sales on a cash basis, a lower short
term credit basis causing a reduction in accounts receivable of Ps. 2,244 million, higher credit from suppliers of Ps. 2,469 million,
offset by higher income taxes paid of Ps. 1,596 million because of higher levels of taxable income.

Our net cash used in investing activities
was Ps. 14,643 million for the year ended December 31, 2012 compared to Ps. 18,089 million for the year ended December 31, 2011,
a decrease of Ps. 3,446 million or 19%.  This decrease was primarily due to the acquisition of Grupo Tampico for Ps. 2,414
million and Grupo CIMSA for Ps. 1,912 million in 2011 whereas the only cash outflow for an acquisition in 2012 was for Grupo Fomento
Queretano of Ps. 1,114 million.

Our net cash used in financing activities
was Ps. 3,418 million for the year ended December 31, 2012 compared to Ps. 6,258 million for the year ended December 31, 2011,
a decrease of Ps. 2,840 million or 45%.  This decrease was primarily due to higher proceeds from bank borrowings in 2012 of
Ps. 14,048 million as compared to Ps. 6,606 million in 2012, offset by higher amounts of payments on bank loans of Ps. 5,872 million
in 2012 as compared to Ps. 3,732 million in 2011 as well as higher dividend payments of Ps. 9,186 million in 2012 compared to Ps.
6,625 million in 2011.

********

Ms. Tia Jenkins, page 4

Also, as requested
by the Staff, the Company acknowledges that:

§
             it is responsible for the adequacy and accuracy of the disclosure in its filings;

§
Staff comments or changes to disclosure in response to Staff comments do not foreclose the SEC 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 SEC or any person under the federal
securities laws of the United States.

Thank you for
your consideration of the Company’s response. If you or any other member of the Staff has any further questions or comments
concerning the response, or if you require additional information, please do not hesitate to contact Duane McLaughlin at Cleary
Gottlieb Steen & Hamilton LLP at (212) 225-2000.

Very truly
yours,

	           /s/ Javier Astaburuaga
Sanjines

Mr. Javier Astaburuaga Sanjines

Chief Financial Officer

Fomento Económico Mexicano, S.A.B.
de C.V.

cc:

Duane McLaughlin

Aaron Saunders

Cleary Gottlieb Steen & Hamilton LLP

June 10, 2014

Via E -mail
Javier Astaburuaga Sanjines
Chief Financial Officer
Mexican Economic Development, Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, NL 64410 Mexico

Re: Mexican Economic Development,  Inc.
 Form 20-F for the Year Ended December 31, 2013
Filed April 16, 2014
File No. 001 -35934

Dear Mr. Sanjines:

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the req uested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide i n
response to these  comments, we may have  additional comments.

Form 20 -F for the Year Ended December 31, 2013

Item 5. Operating and Financial Review and Prospects
Liquidity and Capital Resources, page 72

1. Please provide us with , and confirm t hat you will include in future filings , a more
detailed analysis of the components of the statements of cash flows (i.e. , operating,
investing, and financing activities) that explains the significant year -to-year variations in
each line item (e.g. explain th e significant change in receivables, inventories etc.) for
each period presented.  In this regard, please ensure to  include robust discussions
describing and quantifying the specific effect of the significant causal factors  that
contributed to the material change s in your operating, investing and financing cash flows.
Refer to Item 5 of Form 20 -F and SEC Release No. 33 -8350 as it relates to liquidity and
capital resources for further guidance.

Javier Astaburuaga Sanjines
Mexican Economic Development, Inc.
June 10, 2014
Page 2

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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a com pany’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written 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.

You may contact Suying Li  at (202) 551 -3335  or Raj Rajan at (202) 551 -3388  if you
have questions regarding comments on the financial statements and related matters.

Sincerely,

 /s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining

September 5, 2013

Via E -Mail
Javier Astaburuaga Sanjines
Chief Financial Officer
Mexican Economic Development, Inc.
Colonia Bella Vista
Monterrey, NL 64410
Mexico

Re: Mexican Economic Development, Inc.
 Form 20-F for the Year Ended December 31, 2012
Filed April 8, 2013
File No. 333 -08752

Dear Mr. Sanjines :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to  our comments do not foreclose the Commission from taking
any action with respect to the company or 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 securiti es laws of the United States.  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 the
information the Securities Exchange Act of 1934 and all applicable rules require .

Sincerely,

/s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining

CORRESP
1
filename1.htm

    Unassociated Document

Fomento Económico Mexicano, S.A.B. de C.V.

Ave. General Anaya 601 Pte., Col. Bella Vista

64410 Monterrey, N.L. Mexico

August 28, 2013

VIA FACSIMILE AND EDGAR TRANSMISSION

Ms. Tia L. Jenkins

Senior Assistant Chief Accountant

Office of Beverages, Apparel, and Mining

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Mexican Economic Development, Inc.

Form 20-F for the Fiscal Year Ended December 31, 2012

Filed April 8, 2013

(File No. 333-08752)

Dear Ms. Jenkins:

By letter dated August 15, 2013 (the “Comment Letter”), the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) provided certain comments on the annual report on Form 20-F for the fiscal year ended December 31, 2012, as filed on April 8, 2013 (the “2012 Form 20-F”) by Fomento Económico Mexicano, S.A.B. de C.V. (the “Company”).  We today submit herewith, via facsimile and EDGAR, responses to the Staff’s comments.

For your convenience, we have reproduced below the Staff’s comments in bold and have provided the Company’s response immediately below each comment.

Form 20-F for the Year Ended December 31, 2012

Consolidated Financial Statements

Consolidated Statements of Cash Flows, page F-6

1.

We note you have used “ Income before income taxes and share of the profit of associates and joint ventures accounted for using the equity method” as your starting point to determine cash flows from operating activities. We believe that profit and loss, as defined in IAS 1, is what IAS 7 intended to use to measure cash flows from operating activities. Please tell us why you believe your presentation is in accordance with IAS 7.

Ms. Tia Jenkins, page 2

We believe our presentation is materially consistent with IAS 7 because it is a measure of profit and loss that only excludes two items, income tax and share of the profit of associates and joint ventures accounted for using equity method net of taxes, that are non-cash items. As such, there is no impact on overall cash flows or cash generated from operating activities. Further, if we used net income as the starting point on the statement of cash flows, these two items would be shown as non-cash reconciling items. We are also aware that many companies use pre-tax income as a starting point on the statement of cash flows.  However, we are aware that as a measure of pre-tax profit and loss, the only item it excludes is “share of profit of associates and joint ventures”. This amount is disclosed in our consolidated income statement, and we believe it is not misleading to investors to not start with this amount on the cash flow statement. The only adjustment that we would propose to make to the cash flow statement in future periods would be to start with pre-tax income and show a non-cash adjustment for share of profit from associates and joint ventures. We will make this presentation change in our future filings.

For your information, below is how the measure we use as a starting point would reconcile to pre-tax profit or loss for 2012:

                                                                    2012

Pre-tax profit or loss

36,000

Share of the profit of associates and joint ventures accounted for using the equity method, net of taxes

(8,470)

Income before income taxes and share of the profit of associates and joint ventures accounted for using the equity method

27,530

Notes to the consolidated financial statements

2 Basis of presentation

2.2.1 Presentation of consolidated income statement, page F-7

2.

Since you present costs and expenses by function, please provide additional information about the expenses by nature in accordance with paragraph 104 of IAS 1.

Paragraph 104 mentions “An entity classifying expenses by function shall disclose additional information on the nature of expenses, including depreciation and amortization expense and employee benefits expense”. We have disclosed depreciation and amortization in our Consolidated Statement of Cash Flows and our notes to the consolidated financial statements 11 “Property, Plant and Equipment, Net” and 12 “Intangible Assets, Net”. Long-term employee benefits expenses are disclosed in our note to the consolidated financial statements 16.8 “Post-employment and other long-term employee benefits expense”. We also have disclosed distribution costs and advertising and deferred promotional expenses in our notes to the consolidated financial statements 3.21 “Administrative and selling expenses” and 9.1 “Other current assets”, respectively.

Ms. Tia Jenkins, page 3

In our future filings we will include additional disclosure of the nature of expenses in Note 16.8 and 8 to our consolidated financial statements:

Note 16.8 will include:

Wages and salaries

Social security costs

Employee profit sharing

Post employment benefits (*)

Post employment benefits recognized in other expenses (note 19) (*)

Share-based payments (*)

Termination benefits (*)

 (*) These amounts have already been disclosed in our 2012 Consolidated Financial Statements.

Note 8 “Inventories” will include:

Changes in inventories of finished goods and work in progress

Raw materials and consumables used

********

Ms. Tia Jenkins, page 4

Also, as requested by the Staff, the Company acknowledges that:

§ it is responsible for the adequacy and accuracy of the disclosure in its filings;

§ Staff comments or changes to disclosure in response to Staff comments do not foreclose the SEC 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 SEC or any person under the federal securities laws of the United States.

Thank you for your consideration of the Company’s response.  If you or any other member of the Staff has any further questions or comments concerning the response, or if you require additional information, please do not hesitate to contact Duane McLaughlin at Cleary Gottlieb Steen & Hamilton LLP at (212) 225-2000.

Very truly yours,

/s/ Javier Astaburuaga Sanjines

Mr. Javier Astaburuaga Sanjines

Chief Financial Officer

Fomento Económico Mexicano, S.A.B. de C.V.

cc:

Duane McLaughlin

Aaron Saunders

Cleary Gottlieb Steen & Hamilton LLP

August 15, 2013

Via E -Mail
Javier Astaburuaga Sanjines
Chief Financial  Officer
Mexican Economic Development, Inc.
Colonia Bella Vista
Monterrey, NL 64410
Mexico

Re: Mexican Economic Development, Inc.
 Form 20-F for the Year Ended December 31, 2012
Filed April 8, 2013
File No. 333 -08752

Dear Mr. Sanjines :

We have reviewed your filing an d have the following comments. Please comply with the
following comments in future filings.  Confirm in writing that you will do so and explain to us
how you intend to comply.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information or  by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you pro vide in response to these  comments, we may
have  additional comments

Form 20 -F for the Year Ended December 31, 2012

Consolidated  Financial Statements

Consolidated Statements of Cash Flows, page F -6
1. We note you have used “ Income before income taxes an d share of the profit of associates
and joint ventures accounted for using the equity method” as your starting point to
determine cash flows from operating activities. We believe that profit and loss, as defined
in IAS 1, is what IAS 7 intended to use to m easure cash flows from operating activities .
Please tell us why you believe your presentation is in accordance with IAS 7.

Javier Astaburuaga Sanjines
Mexican Economic Development, Inc.
 August 15, 2013
 Page 2

 Notes to the consolidated financial statements
2 Basis of presentation
2.2.1 Presentation of consolidated income statement, page F -7
2. Since you present costs and expenses by function,  please provide additional information
about the expenses by nature in accordance with paragraph 104 of IAS 1.

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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 t he disclosures they have made.

 In responding to our comments, please provide  a written 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.

You may contact Blaise Rhodes , Staff Accountant,  at (202) 551-3774 or Ivette Leon ,
Assistant Chief Accountant,  at (202) 551-3351  if you have questions regarding comments on the
financial statements and re lated matters.

Sincerely,

/s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining

October 3, 2011

Via E-mail
Juan F. Fonseca
Mexican Economic Development, Inc.
General Anaya No. 601 Pte. Colonia Bella Vista
Monterrey, NL 64410 Mexico

Re: Mexican Economic Development, Inc.
 Form 20-F for Fiscal Year Ended   December 31, 2010
 Filed June 29, 2011
File No. 333-08752

Dear Mr. Fonseca:

We have completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.
 Sincerely,
  /s/ Pamela Howell  for
John Reynolds
Assistant Director

CORRESP
1
filename1.htm

    Unassociated Document

September 14, 2011

VIA FACSIMILE AND EDGAR TRANSMISSION

Mr. John Reynolds

Assistant Director

Division of Corporate Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Re:

Mexican Economic Development, Inc.

Form 20-F for Fiscal Year Ended December 31, 2010

Filed June 29, 2011

File No. 333-08752

Dear Mr. Reynolds:

By letter dated September 6, 2011, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided comments on the annual report on Form 20-F (“Form 20-F”) filed on June 29, 2011 by Mexican Economic Development Inc. (the “Company”).  The Company is submitting today via EDGAR and facsimile responses to the Staff’s comments.

For convenience, we have reproduced below the Staff’s comments and have provided responses immediately below the comments.

Form 20-F for Fiscal Year Ended December 31, 2010

Financial Statements

Notes to Financial Statements

Note 27. Differences Between Mexican FRS and US GAAP

c) Restatement of Prior Year Financial Statements for Inflationary Effects, page F-55

1.

We note from your disclosure that you have applied an accommodation under Item 17(c)(2)(iv)(B) of the instructions to the Form 20-F in which the U.S GAAP reconciliation is not required to be provided if you translate amounts in your financial statements stated in a currency of a hyperinflationary economy into your reporting currency in accordance with IAS 21. This appears to be inconsistent with your disclosure on page F-11 which states that you are accounting for the effects of inflation under the guidance of NIF B-10. Please clarify or revise. If you are applying the guidance of IAS 21 and IAS 29 please provide the disclosure required by Item 17(c)(2)(iv)(C) of the instructions to the Form 20-F. If not, please provide the required U.S. GAAP reconciliation. Please advise or revise.

John Reynolds

September 14, 2011, page 2

Response

As disclosed in Note 3 i) of our consolidated financial statements, in accordance with Mexican FRS, FEMSA recognizes inflation effects under MFRS B-10, “Inflation Effects”, when the cumulative inflation of an economic environment of the three proceeding years is equal to or greater than 26%.  In 2010, inflationary economies in which FEMSA operates, according to Mexican FRS, are Venezuela, Nicaragua, Costa Rica and Argentina.

As explained in the second paragraph to Note 27 c) of our financial statements, these inflationary effects result in a difference to be reconciled from Mexican FRS to U. S. GAAP.  Specifically, the inflation effects reversed in the reconciliation of net income and stockholders’ equity from Mexican FRS to U.S. GAAP in our financial statements only represent the inflationary effect of Nicaragua, Costa Rica and Argentina.

Our Venezuelan operations meet the hyperinflationary economy criterion of the FASB Accounting Standards codification paragraph 830-10-45-11 as disclosed in the third paragraph of Note 27 c).  Because MFRS B-10 complies with  the indexation approach of International Accounting Standard 21, Changes in Foreign Exchange Rates (IAS 21) and IAS 29, Financial Reporting in Hyperinflationary Economies (IAS 29) and Venezuela is a hyperinflationary economy, it is eligible for the accommodation under Item 17(c)(2)(iv)(B) of the instructions to the Form 20-F.  As disclosed in the fourth paragraph to Note 27 c), U.S GAAP reconciliation is not required to be provided using this accommodation if you translate amounts in your financial statements stated in a currency of a hyperinflationary economy into your reporting currency in accordance with IAS 21.  As such, we believe the disclosures in Note 27 c) of our financial statements meet the disclosures required by Item 17(c)(2)(iv)(C) of the instructions to the Form 20-F.

Exhibits

2.           Exhibit 1.4 appears to be missing exhibits, schedules or attachments. Please confirm that you will file this agreement in its entirety with your next periodic report or advise.

Response

Based on the Staff’s comment, the Company confirms that it will file Exhibit 1.4 in its entirety with its next periodic report, which will be its annual report on Form 20-F for the year ending December 31, 2011.

*  *  *

As requested by the Staff, the Company makes the following acknowledgments:

·

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

John Reynolds

September 14, 2011, page 3

·

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.

If you have any questions or require any additional information with respect to the above, please do not hesitate to contact Duane McLaughlin at Cleary Gottlieb Steen & Hamilton LLP at (212) 225-2106.

John Reynolds

September 14, 2011, page 4

Sincerely,

/s/ Javier Astaburuaga Sanjines

Javier Astaburuaga Sanjines

Executive Vice-President of Finance and

Strategic Development / Chief Financial

Officer

cc:

Angela Halac

Brian K. Bhandari

Erin Wilson

Pamela Howell

Securities and Exchange Commission

Duane McLaughlin

Cleary Gottlieb Steen & Hamilton LLP

C.P.C. Víctor Luis Soulé García

Mancera, S.C., Member of Ernst and Young Global

September 6, 2011

Via E-mail
Juan F. Fonseca
Mexican Economic Development, Inc.
General Anaya No. 601 Pte. Colonia Bella Vista
Monterrey, NL 64410 Mexico

Re: Mexican Economic Development, Inc.
 Form 20-F for Fiscal Year Ended   December 31, 2010
 Filed June 29, 2011
File No. 333-08752

Dear Mr. Fonseca:

We have reviewed your filing and have the following comments.  In some of our comments,
we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten busin ess days by amending your filing, by providing
the requested information, or by advising us when you will provide the requested response.  If you do
not believe our comments apply to your facts and circumstances or do not believe an amendment is
appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in response to
these comments, we may have additional comments.

Form 20-F for FYE December 31, 2010

Financial Statements
Notes to Financial Statements
Note 27.  Differences Between Mexican FRS and US GAAP
c) Restatement of Prior Year Financial Stat ements for Inflationary Effects, page F-55

1. We note from your disclosure that you have applied an accommodation under Item
17(c)(2)(iv)(B) of the instructions to the Form 20-F in which the U.S GAAP reconciliation is
not required to be provided if you translate amount s in your financial statements stated in a
currency of a hyperinflationary economy into  your reporting currency in accordance with
IAS 21.  This appears to be inconsistent with your disclosure on page F-11 which states that
you are accounting for the effects of inflation under the guidance of NIF B-10.  Please clarify
or revise.  If you are applying the guidance of IAS 21 and IAS 29 please provide the
disclosure required by Item 17(c)(2)(iv)(C) of the instructions to the Form 20-F.  If not,
please provide the required U.S. GAAP reconciliation.  Please advise or revise.

Juan F. Fonseca Mexican Economic Development, Inc. September 6, 2011 Page 2

 Exhibits

2. Exhibit 1.4 appears to be missing exhibits, schedules or attachments.   Please confirm that
you will file this agreement in its entirety with your next periodic report or advise.
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 the information the Securities Exchange Act of 1934
and all applicable Exchange Act rules require.  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 responding to our comments, please provide a written 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.

You may contact Angela Halac at (202) 551-3398 or Brian Bhandari at (202) 551-3390 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Erin Wilson at (202) 551-6047 or Pamela Howell at (202) 551-3357 with any other
questions.

Sincerely,

 /s/ Pamela Howell
 for

 John Reynolds
Assistant Director

Mail Stop 3561        August 27, 2009
Mr. Jose Antonio Fernandez Carbajal Chief Executive Officer Fomento Economico Mexicano, S.A.B. de C.V. General Anaya No 601 Pte. Colonia Bella Vista Monterrey, NL 64410 Mexico
 Re:       Fomento Economico Mexicano, S.A.B. de C.V.
   Form 20-F for the Year Ended December 31, 2008
   Filed June 30, 2009
   File No. 333-08752

Dear Mr. Carbajal:
 We have completed our review of your Form 20-F and related filings and have no
further comments at this time.
 Sincerely,    Brian Bhandari Branch Chief Office of Beverages, Apparel, and  Health Care Services

CORRESP
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filename1.htm

[Fomento Económico Mexicano, S.A.B. de C.V. letterhead]

August 20, 2009

VIA FACSIMILE AND EDGAR TRANSMISSION

Ms. Tia Jenkins

Senior Assistant Chief Accountant

Office of Beverages, Apparel and Health Care Services

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

            Re:

            Fomento Económico Mexicano, S.A.B. de C.V.

Form 20-F for the Year Ended December 31, 2008

Filed June 30, 2008

File No. 333-08752

Dear Ms. Jenkins:

By letter dated August 10, 2009, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided comments on the annual report on Form 20-F (“Form 20-F”) filed on June 30, 2009 by Fomento Económico Mexicano, S.A.B. de C.V. (“FEMSA”).  FEMSA is submitting today via EDGAR and facsimile responses to the Staff’s comments.

For convenience, we have reproduced below the Staff’s comment and have provided a response immediately below the comment.

Form 20-F for the Fiscal Year Ended December 31, 2008

Notes to the Consolidated Financial Statements

Note 26.  Differences Between Mexican FRS and U.S GAAP (F-48)

It appears that your disclosure in Note 2 (b) on F-10 that the criteria under Mexican FRS for determining an inflationary environment in when the cumulative inflation for the preceding three years is 26% of more.  This criteria appears to be inconsistent with the criteria under US GAAP, particularly for your subsidiaries in Nicaragua, Costa Rica and Argentina.  Per the guidance of paragraph 830-10-45-11 of the FASB’s Accounting Standards Codification, an inflationary economy is one in which the cumulative inflation for the preceding three years is greater than 100%.  Please show us where you have presented the reconciling item for such difference, or tell us why such item is not necessary.

            1

Ms. Tia Jenkins, page 2

As disclosed in Note 2 b) of our consolidated financial statements, in accordance with Mexican FRS FEMSA recognizes inflation effects under MFRS B-10 “Inflation Effects” when the cumulative inflation of an economic environment of the three proceeding years is equal to or greater than 26%.  In 2008, inflationary economies in which FEMSA operates, according to Mexican FRS, are Venezuela, Nicaragua, Costa Rica and Argentina.  These operations are conducted through our subsidiary Coca-Cola FEMSA, S.A.B. de C.V. (“KOF”).

While FEMSA consolidates KOF for purposes of Mexican FRS, FEMSA does not consolidate KOF for U.S. GAAP purposes in accordance with EITF 96-16 “Investor’s Accounting for an Investee When the Investor Has a Majority of the Voting Interest but the Minority Shareholder or Shareholders Have Certain Approval or Veto Rights” as explained in Note 26 of our consolidated financial statements.  The stand-alone U.S. GAAP financial information of KOF is recognized in FEMSA through the equity method, which is disclosed as  “Participation in Coca-Cola FEMSA” in the Reconciliation of Net Income and in the Reconciliation of Stockholders’ Equity in Note 27 a) and b), respectively, of our consolidated financial statements.

As a result, reconciliation of inflation effects for those countries that do not meet the inflation criteria according to paragraph 830-10-45-11 of the FASB’s Accounting Standards Codification, is explained in Note 26 of the Coca-Cola FEMSA’s consolidated financial statements as follows:

a) Restatement of Prior Year Financial Statements:

Under US GAAP, the Company applies the regulations of the Securities and Exchange Commission of the United States of America (“SEC”), which allowed to the Company to not reconcile prior years’ financial statements for inflation through December 31, 2007 because they were comprehensively restated in constant units of the reporting currency.

Beginning on January 1, 2008, in accordance with NIF B-10, the Company discontinued inflationary accounting for subsidiaries that operate in non-inflationary economic environments. The cumulative effect of previously realized and unrealized results of holding non-monetary assets (RETANM) of previous periods was reclassified to retained earnings as described in Note 2 b). This reclassification does not result in a difference to reconcile for U.S. GAAP purposes since those amounts are ultimately recognized in the Company’s financial statements.

Beginning in 2008, as a result of discontinuing inflationary accounting for subsidiaries that operate in non-inflationary economic environments, the financial statements are no longer considered to be presented in a reporting currency that comprehensively includes the effects of price level changes; therefore, the effects of inflation generated beginning in 2008 result in a difference to be reconciled for US GAAP purposes.

The inflation effects reversed in the reconciliation of net income and stockholders equity of Mexican FRS to U.S. GAAP disclosed in Note 27 a) and b) of the consolidated financial statements of Coca-Cola FEMSA were Ps. 356 million and Ps. 2,153 million, respectively.

Ms. Tia Jenkins, page 3

*  *  *

            As requested by the Staff, FEMSA makes the following acknowledgments:

            •

            FEMSA 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

            •

            FEMSA 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.

If you have any questions or require any additional information with respect to the above, please do not hesitate to contact the undersigned at (52) 81 8328 6010.

 Sincerely,

/s/ Javier Astaburuaga Sanjines

Javier Astaburuaga Sanjines

Executive Vice-President of Finance

and Strategic Development / Chief Financial Officer

cc:

Duane McLaughlin

Cleary Gottlieb Steen & Hamilton LLP

Victor Luis Soulé Garcia

    Mancera, S.C., A Member Practice of Ernst and Young Global

Mail Stop 3561        August 10, 2009
Mr. Jose Antonio Fernandez Carbajal Chief Executive Officer Fomento Economico Mexicano, S.A.B. de C.V. General Anaya No 601 Pte. Colonia Bella Vista Monterrey, NL 64410 Mexico
 Re:       Fomento Economico Mexicano, S.A.B. de C.V.
   Form 20-F for the Year Ended December 31, 2008
   Filed June 30, 2009
   File No. 333-08752

Dear Mr. Carbajal:
 We have reviewed your filing and have the following 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 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 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 on 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 Fiscal Year Ended December 31, 2008

Notes to the Consolidated Financial Statements

Note 26. Differences between Mexican FRS and U.S. GAAP, F-48

1. It appears from your disclosure in Note 2(b) on F-10 that the criteria under
Mexican FRS for determining an inflationary environment is when the cumulative
inflation of the three preceding years is 26% or more.  This criteria appears to be inconsistent with the criteria under US GAAP, particularly for your subsidiaries

Jose Antonio Fernandez Carbajal
Fomento Economico Mexicano, S.A.B. de C.V.
August 10, 2009 Page 2
in Nicaragua, Costa Rica, and Argentina.  Per the guidance in paragraph 830-10-45-11 of the FASB Accounting Standards Codification, an inflationary economy is one in which the cumulative
 inflation of the three preceding years is greater
than 100%.  Please show us where you have presented the reconciling item for such difference or tell us why such item is not necessary.

 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provide us with a response.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment 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 amendment and 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 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.

In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.

Jose Antonio Fernandez Carbajal
Fomento Economico Mexicano, S.A.B. de C.V. August 10, 2009 Page 3

You may contact William J. Kearns, St aff Accountant, at (202) 551-3727 or
Angela Halac, Senior Staff Accountant, at (202) 551-3398 if you have any questions.

Sincerely,    Tia Jenkins Senior Assistant Chief Accountant Office of Beverages, Apparel, and Health Care Services

Mail Stop 3561

            October 25, 2007

By Facsimile and U.S. Mail

 Javier Astaburuaga Sanjines Executive Vice President of Finance   and Strategic Development Fomento Económico Mexicano, S.A.B. de C.V. General Anaya No. 601 Pte.  Colonia Bella Vista Monterrey, NL 64410 Mexico
 Re: Fomento Económico Mexicano, S.A.B. de C.V.  Form 20-F for Fiscal Year Ended December 31, 2006  Filed June 28, 2007            File No. 333-08752

Dear Mr. Sanjines:
  We have completed our review of your Form 20-F and have no further comments
at this time.            S i n c e r e l y ,             M i c h a e l  M o r a n          A c c o u n t i n g  B r a n c h  C h i e f

CORRESP
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    October 22, 2007

        VIA FACSIMILE AND EDGAR TRANSMISSION

        Mr. Michael Moran

        Accounting Branch Chief

        Division of Corporation Finance

        Securities and Exchange Commission

      100 F Street, N.E.

        Washington, D.C. 20549

    Re:
    Fomento Económico Mexicano, S.A.B. de C.V.

        Form 20-F for Fiscal Year Ended December 31, 2006

        File No. 333-08752

    Dear Mr. Moran:

        By letter dated September 24, 2007, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided comments on the annual report on Form 20-F (“Form 20-F”) filed on June 28, 2007 by Fomento Económico Mexicano, S.A.B. de C.V. (the “Company”). The Company is submitting today via EDGAR and facsimile responses to the Staff’s comments.

        For convenience, we have reproduced below the Staff’s comments and have provided responses immediately below the comments.

        Cover page

        1.            Our records indicate your file number is 333-08752 rather than 1-14814. Please advise or revise the cover page in future filings.

        We note the Staff’s comment and will revise our future filings to reflect the correct file number.

        Note 4. Significant Accounting Policies, page F-9

        e) Bottles and Cases, page F-10

2.            Please tell us why the change in accounting treatment for returnable bottles and cases is not disclosed as a change in accounting principle as described in paragraphs 7 - 9 of APB 20. If so, you are required to disclose the impact of the change in principle on deferred taxes, equity, income before extraordinary items, net income and related per share amounts. See paragraph 19 of APB 20. Also tell us if you are required to provide a letter of preferability from your independent public accountant stating whether or not the change in accounting principle is preferable under the circumstances.

It is our understanding that the applicable guidance of APB 20 has been superseded by SFAS 154 as it relates to our December 31, 2006 financial statements and therefore our response to the Staff’s comment will be based on references to such standard.  We note the Staff’s comment and respectfully advise the Staff that, although we are familiar with the definition of Paragraph 2c) of FASB 154 with respect to what constitutes a change in accounting principle, the Company’s change in balance sheet classification for returnable bottles and cases did not impact deferred taxes, equity, income before extraordinary items, net income or per share amounts for any period covered in the Form 20-F, and therefore we believe that no additional disclosure is required.  The disclosure requirements for a change in accounting principle, as discussed in Paragraph 17b) of FASB 154, refer to
changes that are reflected in net income and related per share amounts, income from operations, net assets or performance, retained earnings and other equity components on the company’s financial statements.  This change in classification, however, had no impact on our accounting estimates for bottles and cases and no change was generated in deferred taxes, equity, income before extraordinary items, net income or related per share amounts.

In response to the Staff's comment regarding preferability, we respectfully submit that it is our understanding that foreign private issuers such as the Company that file a Form 20-F are not required to provide a letter of preferability from their independent public accountants regarding changes in accounting. Our understanding is based on information included in section V.H. of the International Reporting and Disclosure Issues, which states the following: "Form 20-F does not have a requirement for a preferability letter."

R) Cumulative Other Comprehensive Income, page F-14

3.            In future filings please also disclose the income tax effects for either the components or total other comprehensive income items, as applicable. See paragraph 24 of SFAS No. 130.

We note the Staff’s comment and advise the Staff that we will incorporate the information required by paragraph 24 of FASB 130 in our future filings.

Note 27. Differences between Mexican FRS and U.S. GAAP, page F-38

a) Consolidation of Coca-Cola FEMSA, page F-39

4.            You are required to explicitly disclose which of the audit firms is responsible for the summarized financial information presented under U.S. GAAP in 27.a) and the participating adjustments in 28.a) and b). See V.J. of the International Reporting and Disclosure Issues in the Division of Corporation Finance.

We note the Staff’s comment and respectfully advise the Staff that, as explicitly stated in the auditor’s report attached as page F-2 to the Company’s Form 20-F, the Company’s principal auditor is Galaz, Yamazaki, Ruiz Urquiza, S.C., member of Deloitte Touche Tohmatsu. The auditor of our subsidiary Coca-Cola FEMSA, S.A.B. de C.V. and subsidiaries (“Coca-Cola FEMSA”) is also Galaz, Yamazaki, Ruiz Urquiza, S.C.  The auditor of our wholly-owned subsidiary FEMSA Comercio, S.A. de C.V. and subsidiaries (“FEMSA Comercio”) is Mancera, S. C., a member practice of Ernst & Young Global as stated in their report included in our 20-F.  The scope section of the audit opinion of Galaz, Yamazaki, Ruiz Urquiza, S.C. makes reference to the report of such other auditors as it relates to the consolidated financial statements of FEMSA Comercio.

Section V.J. of the International Reporting and Disclosure Issues in the Division of Corporate Finance addresses the division of responsibility between auditors as it relates to the preparation of financial statements using different accounting standards.  The summarized financial information presented under U.S. GAAP in Note 27.a) and the participating adjustments in 28.a) and b) as they relate to Coca-Cola FEMSA are also subject to the audit performed by Galaz, Yamazaki, Ruiz Urquiza, S.C.  They audit both FEMSA’s consolidated financial statements and Coca-Cola FEMSA’s financial statements and therefore there is no division of responsibility for the audit of this subsidiary.

The participating U.S. GAAP adjustments presented in Notes 28.a) and b) as they relate to FEMSA Comercio are subject to the audit performed by Mancera, S.C.  The audit report of Mancera, S. C. clearly states that they have audited the financial statements of FEMSA Comercio, which are presented in accordance with Mexican Financial Reporting Standards and include a footnote reconciliation to U.S. GAAP.  Therefore, we believe and respectfully submit that the division of responsibility between Galaz, Yamazaki, Ruiz Urquiza, S.C and Mancera, S.C. is clearly disclosed in their respective audit opinions and that no additional disclosures are necessary.

*  *  *

            As requested by the Staff, the Company makes the following acknowledgments:

            •

            the Company is responsible for the adequacy and accuracy of the disclosure in its filings;

            •

            Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff 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.

If you have any questions or require any additional information with respect to the above, please do not hesitate to contact Duane McLaughlin at Cleary Gottlieb Steen & Hamilton LLP at (212) 225-2000.

Sincerely,

/s/ JAVIER ASTABURUAGA SANJINES

Javier Astaburuaga Sanjines

Executive Vice President of Finance

and Strategic Development and

Chief Financial Officer

            cc:

Duane McLaughlin

Cleary Gottlieb Steen & Hamilton LLP

Gabriel González Martínez

            Deloitte Touche Tohmatsu

CORRESP
1
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[FEMSA Letterhead]

            October 9, 2007

VIA EDGAR AND FACSIMILE

Mr. Michael Moran

Accounting Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

            Re:

            Fomento Económico Mexicano, S.A.B. de C.V.

            Form 20-F for Fiscal Year Ended December 31, 2006

          File No. 333-08752

Dear Mr. Moran:

By letter dated September 24, 2007 (the “Comment Letter”), the staff of the Securities and Exchange Commission (the “Staff”) provided certain comments to the annual report on Form 20-F for the fiscal year ended December 31, 2006, as filed on June 28, 2007 by Fomento Económico Mexicano, S.A.B. de C.V. (the “Company”).  The Staff has requested that the Company respond to the Comment Letter within ten (10) business days or otherwise inform the Staff when we will respond.

We have reviewed the Comment Letter and are in the process of preparing our response.  We intend to submit such response to you no later than October 22, 2007.

Thank you for your consideration.  If you or any other member of the Staff has any questions, please do not hesitate to contact Duane McLaughlin or Matthew Stitzer, our outside legal counsel, at Cleary Gottlieb Steen & Hamilton LLP at (212) 225-2000.

Very truly yours,

/s/  Javier Astaburuaga Sanjines

Javier Astaburuaga Sanjines

Executive Vice President of Finance

and Strategic Development and

Chief Financial Officer

            cc:

            Duane McLaughlin, Esq.

      Cleary Gottlieb Steen & Hamilton LLP

Mail Stop 3561

                 September 24, 2007

By Facsimile and U.S. Mail

 Javier Astaburuaga Sanjines Executive Vice President of Finance   and Strategic Development Fomento Económico Mexicano, S.A.B. de C.V. General Anaya No. 601 Pte.  Colonia Bella Vista Monterrey, NL 64410 Mexico

Re: Fomento Económico Mexicano, S.A.B. de C.V.  Form 20-F for Fiscal Year Ended December 31, 2006  Filed June 28, 2007            File No. 333-08752
Dear Mr. Sanjines:
  We have reviewed the above referenced filing and have the following comments.  We have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your document.  Please provide a written response to our comments.  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 the purpose of our review 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.

Mr. Javier Astaburuaga Sanjines
Fomento Económico Mexicano, S.A.B. de C.V. September 24, 2007 Page 2
 Cover page

 1. Our records indicate your file number is 333-08752 rather than 1-14814.  Please advise or revise the cover page in future filings.
 Note 4. Significant Accounting Policies, page F-9

e) Bottles and Cases, page F-10

2. Please tell why the change in accounting treatment for returnable bottles and cases is not disclosed as a change in accounting principle as described in paragraphs 7 -9 of APB 20.  If so, you are required to disclose the impact of the change in principle on deferred taxes, equity, income before extraordinary items, net income and related per share amounts.  See paragraph 19 of APB 20.  Also tell us if you are required to provide a letter of preferability from your independent public accountant stating whether or not the change in accounting principle is preferable under the circumstances.

R) Cumulative Other Comprehensive Income, page F-14

3. In future filings please also disclose the income tax effects for either the components or total other comprehensive income items, as applicable.  See paragraph 24 of SFAS No. 130.

Note 27. Differences between Mexican FRS and U.S. GAAP, page F-38

a) Consolidation of Coca-Cola FEMSA:, page F-39

4. You are required to explicitly disclose which of the audit firms is responsible for the summarized financial information presented under U.S. GAAP in 27.a) and the participating adjustments in 28.a) and b).  See V.J. of the International Reporting and Disclosure Issues in th e Division of Corporation Finance.
   Please respond to these comments within 10 business days or tell us when you will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested information.  Detailed letters greatly facilitate our review.  File your response on EDGAR as a correspondence file.  Please understand that we may have additional comments after reviewing your responses to our comments.

Mr. Javier Astaburuaga Sanjines Fomento Económico Mexicano, S.A.B. de C.V. September 24, 2007 Page 3

   We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing 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 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 th e Division of Corporation Finance in our
review of your filing or in response to our comments on your filing.
   You may contact Brian McAllister, St aff Accountant at (202) 551-3341, or me at
(202) 551-3841 if you have any questions regarding comments on the financial statements and related matters.            S i n c e r e l y ,              M i c h a e l  M o r a n           Accounting Branch Chief