June 8, 2006


Mr. Hirokazu Nara
Director and Principal Financial Officer, Kubota Corp.
2-47, Shikitsuhigashi 1-chome,
Naniwa-ku Osaka, 556-8601 Japan


Re:	Kubota Corporation
Form 20-F for the fiscal year ended March 31, 2005
      File No. 1-07294

Dear Mr. Nara:

      We have reviewed your response to our letter dated May 9 and
have the following comments.  We ask that you respond by June 22,
2006.

      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.

Note 13. Supplemental Expense Information - Loss (Gain) from
Disposal
and Impairment of Business and Fixed Assets, page 46

1. We note your response letter dated May 11, 2006 in which you
indicate that you will be filing an amended 20-F for the period
ended
March 31, 2005.  Prior to filing that amendment, please provide us
with a sufficiently detailed analysis of SFAS 144 so that we may
understand the appropriateness of your conclusion the subsidiary
that
operated the golf course should be reflected as a discontinued
operation as of March 31, 2005 while the subsidiary that operated
a
rental computer service business should not be reflected as a
discontinued operation.

	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 provide us with a supplemental response
letter that keys your responses to our comments and provides any
requested supplemental information.  Detailed letters greatly
facilitate our review.  Please file your supplemental response on
EDGAR as a correspondence file.  Please understand that we may
have
additional comments after reviewing your responses to our
comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Securities and
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.

If you have any questions regarding these comments, please direct
them
to Mindy Hooker, Staff Accountant, at (202) 551-3732, Jeanne
Baker,
Assistant Chief Accountant, at (202) 551-3691 or to the
undersigned at
(202) 551-3768.


Sincerely,



John Cash
Branch Chief
Mr. Nara
Kubota Corp.
June 8, 2006
Page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE