UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

Mail Stop 5546
								November 16, 2006

Via Facsimile 011 31 20 59 77 150 and US Mail

G.J. Kleisterlee
President
Royal Philips Electronics
Breitner Center, Amstelplein 2
1096 BC Amsterdam,
The Netherlands

	Re:	Royal Philips Electronics
		Form 20-F for the Fiscal Year Ended December 31, 2005
      Filed February 13, 2006
 		Response Letter dated October 19, 2006
      File No. 1-05146

Dear Mr. Kleisterlee:

      We have reviewed your response dated October 19, 2006 and
have
the following comments.  After reviewing this information, we may
or
may not raise additional comments.  Feel free to call us at the
telephone numbers listed at the end of this letter.

General

1. We note your reference to U.S. policies approving sales of
medical
products and the statement that such sales should not carry the
reputational risk of other products, "such as dual use items or
other
products that are barred by either the OFAC sanctions or the EAR."
Please note that medical products may incorporate technology that
presents dual-use concerns.  Please expand your description of the
nature of your product sales, including but not limited to medical
product sales, to address whether, to the best of your knowledge
and
belief, any of your products sold into the referenced countries
incorporate any dual-use items or technology.  If, to the best of
your knowledge and belief, none of your products sold in
connection
with your operations described in your October 19 letter include
dual-use items or technology, please so state.  To the extent your
response identifies dual-use items or technology, please also
expand
your qualitative materiality analysis to address such sales.

2. Please confirm that your qualitative materiality analysis takes
into account the broadened Iran sanctions adopted in the Iran
Freedom
Support Act signed in September 2006, or expand your analysis to
address the effect, if any, that you believe the broadened
sanctions
may have on your sales to and contacts with Iran.

3. We note the statement that you have several local distributors
in
Iran and Syria.  Please tell us, to the best of your knowledge and
belief, whether the governments of these countries or entities
controlled by them receive financing or act as intermediaries in
connection with your sales into or contacts with such countries.

4. We note your description of product sales into Venezuela
purchased
through Cimex Corporation of Cuba.  Please tell us whether, to the
best of your knowledge and belief, any of the products that you
deliver to Venezuela are later sold or delivered to Cuba.  To the
extent you know or believe that your medical products are
indirectly
sold to Cuba through Venezuela, please expand your quantitative
and
qualitative materiality analysis to address such contacts.


      Please contact James Lopez at (202) 551-3536 if you have any
questions about the comments or our review.  You may also contact
me
at (202) 551-3470.



								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk




cc: 	Peggy Fisher
		Assistant Director
		Division of Corporation Finance
G.J. Kleisterlee
Royal Philips Electronics
Page 1