June 22, 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 June 8 and have the following 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. Note 13. Supplemental Expense Information - Loss (Gain) from Disposal and Impairment of Business and Fixed Assets, page 46 1. We appreciate your response in your letter dated June 22, 2006. Based on the information you have provided, we do not object to your conclusions that the results of operations of the golf course business should have been reflected as a discontinued operation as of March 31, 2005 while the operations of the disposed rental computer server business did not require discontinued operations presentation. 	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 22, 2006 Page 1 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE