Mail Stop 3561
							September 22, 2005
Mr. Ricardo Reyes
CFO
Compania Cervecerias Unidas S.A.
Bandera 84, Sixth Fllor
Santiago, Chile

Re:	United Breweries Company, Inc.
      Form 20-F for the Fiscal Year Ended December 31, 2004
      File No. 1-14906

Dear Mr. Reyes:

            We have reviewed your filing and have the following
comments.  Where indicated, we think you should revise your
documents
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
filings.  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.

Note 1 - Nature of Operations and Summary of Significant
Accounting
Policies, page F-8
m) Translation of Foreign Currency Financial Statements, page F-14
1. We note that your accounting policy regarding the financial
statements of your subsidiaries in Argentina differs from the
accounting treatment required under US GAAP as outline in SFAS 52.
Tell us what is the functional currency of your Argentinean
subsidiaries under US GAAP.  If the functional currency is not the
Argentine Peso,  tell us how you account for gains and losses that
arise as a result of remeasurement.  If the functional currency is
the Argentine Peso for US GAAP, please explain to us the
similarity
in the translation adjustment under both US and Chilean GAAP given
the differing requirement of SFAS 52 and Technical Bulletin 64.

v) Advertising and Sales Promotion Costs, page F-17
2. In your note reconciling US GAAP to Chilean GAAP, please
disclose
your policy for advertising costs under SOP 93-7.  Also, please
disclose the total amount expensed for advertising for each period
presented as well as the total amount reported as assets.  See
paragraph 49 of SOP 93-7.

Goodwill, page F-47
3. In future filings, please disclose your goodwill and any
changes
that occur during the periods presented by segment. Please see
paragraph 45 of SFAS 142.

Additional Disclosure Requirements, page F-61
4. We note your disclosures regarding selling and administrative
expenses.  We note that there is no requirement under US GAAP to
classify shipping and handling costs as cost of sales and this is
a
policy decision under EITF 00-10.  Please revise your disclosures
in
future filings.

* * *

       As appropriate, please amend your filings 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 filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

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

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

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

      You may contact me at (202) 551-3841 if you have questions
regarding the comments.


      Sincerely,


	Michael Moran
      Branch Chief


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Ricardo Reyes
Compania Cervecerias Unidas S.A.
September 22, 2005
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