Mail Stop 0308
								August 2, 2005

Mr. Gary P. Fayard
Executive Vice President and Chief Financial Officer
The Coca-Cola Company
One Coca-Cola Plaza
Atlanta, Georgia  30313

		RE:	The Coca-Cola Company
			Form 10-K for the fiscal year ended December 31,
2004
			Filed March 4, 2005

Dear Mr. Fayard:

      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 a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operation, page 24

Application of Critical Accounting Policies, page 31

1. We have reviewed your response to prior comment 2 of our letter
dated April 27, 2005.  Please help us understand your basis for
determining that your operations in Germany and the Nordic region
should be aggregated and deemed a single reporting unit for
goodwill
impairment testing purposes.  In this regard, please discuss the
impact of economic situation in Germany as compared to that of the
Nordic region, including the impact of Germany`s participation in
the
euro, on your operations.  See paragraph 30 of SFAS No. 142.
Please also clarify for us whether you would have recognized
goodwill
impairment related to CCEAG if Germany were a single reporting
unit.

Item 8.  Financial Statements and Supplementary Data, page 60

Note 1.  Organization and Summary of Significant Accounting
Policies,
page 66

Variable Interest Entities, page 66

2. We note your response to prior comment 4 of our letter dated
April
27, 2005, and the additional information you provided on July 14,
2005.  We are in the process of further considering this issue and
will contact you in due course.


       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.  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.

	You may contact Nili Shah at (202) 551-3255 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3716 with any other
questions.


      Sincerely,



      Will Choi
      Accounting Branch Chief





??

??

??

??

Mr. Gary P. Fayard
Executive Vice President and Chief Financial Offier
The Coca-Cola Company
August 2, 2005
Page 2



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE