March 21, 2005

Via U.S. Mail

Satoshi Tanaka, General Manager
Investor Relations Division
Mitsui & Co., Ltd.
2-1, Ohtemachi 1-chome,
Chiyoda-ku, Tokyo 100-0004, Japan

RE:		Mitsui & Co., Ltd.
      Form 20-F for the fiscal year ended March 31, 2004
      Response letter dated February 24, 2005
		File No. 0-09929


Dear Mr. Tanaka:

      We have reviewed the above filing and response letter and
have
the following comment.  We have limited our review of your Form
20-F
to disclosures relating to your contacts with countries that have
been identified as state sponsors of terrorism, and will make no
further review of the Form 20-F.  Our review with respect to this
issue does not preclude further review by the Assistant Director
group with respect to other issues.  At this juncture, we are
asking
you to provide us with supplemental information, so that we may
better understand your disclosure.  Please be as detailed as
necessary in your response. After reviewing this information, we
may
or may not 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 comment or on any other
aspect
of our review.  Feel free to call us at the telephone number
listed
at the end of this letter.



General -
Your response to our prior comment does not indicate that you
considered the impact your ties to a country identified by the
U.S.
State Department as a state sponsor of terrorism, and subject to
U.S.
economic sanctions, might have upon your reputation and share
value.
Please give us your view of the materiality of your Iran-related
operations, and whether they pose a material investment risk to
your
security holders, in light of these additional non-quantitative
factors.

Closing

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact me at (202)
942-
7817 if you have any questions about the comment or our review.


								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk


cc: 	Roger Schwall
		Assistant Director
		Division of Corporation Finance
Mitsui & Co., Ltd.
March 21, 2005
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0507

         DIVISION OF
CORPORATION FINANCE