UPLOAD: SEC-generated letter

November 22, 2005

Room 7010

Raymond J. Seabrook
Sr. Vice President and Chief Financial Officer
Ball Corporation
10 Longs Peak Drive, PO Box 5000
Broomfield, Colorado 80021-2510

Re: Ball Corporation
Form 10-K for Fiscal Year Ended December 31, 2004
Forms 10-Q for the Fiscal Quarters Ended April 3, 2005 and July 3,
2005
File No. 001-07349

Dear Mr. Seabrook:

We have reviewed the above referenced filing and have the
following comments. Please note that we have limited our review
to
the matters addressed in the comments below. We may ask you to
provide us with supplemental information so we may better
understand
your disclosure. Please be as detailed as necessary in your
explanation. 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 filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for Fiscal Year Ended December 31, 2004

2. Business Segment Information
1. You disclose that you operate in three segments, North American
packaging, international packaging and aerospace and technologies.
However, in your business section and MD&A you separately discuss
product lines such as North American metal beverage containers,
North
American metal food containers and North American plastic
containers.
Please tell us the factors used to identify the Company`s
reportable
segments and explain why you believe that North American metal
beverage, North American metal food and North American plastics
are
not separate reportable segments pursuant to paragraphs 10-17 of
SFAS
No. 131. See also paragraph 26 of SFAS 131.

Form 10-Q for the Quarter Ended July 3, 2005

Accounts Receivable
2. We note that your accounts receivable balance increased 56%
during
the six months ending July 3, 2005. We further note that your
receivable days sales outstanding has increased from 22.9 days at
December 31, 2004 to 33.9 days at July 3, 2005. Regarding your
accounts receivable balances, tell us the following:

* The reasons for the increases in your accounts receivable
balances
in recent periods;

* The factors that led to the increase in days sales outstanding;

* The extent to which you have successfully collected these
amounts
subsequent to the balance sheet dates;

* Whether you had any significant delinquent or disputed accounts
that you have written off; and,

* What consideration, if any, was given to disclosing the above
information in your liquidity section of your Form 10-Q.

Please note that your liquidity section should include a detailed
discussion and analysis regarding the trends and uncertainties
surrounding the collectibility of accounts receivable, including
why
your day sales outstanding significantly increased when compared
to
the prior period. Refer to Item 303 (A) (1) of Regulation S-K for
disclosure requirements and guidance as well as the Commission`s
MD&A
Interpretive Release 33-8350.

Shareholders Equity
3. You disclose in your Form 10-K that on January 31, 2005 you
repurchased three million of your outstanding shares in a
privately
negotiated accelerated stock repurchase transaction. Explain to
us
the terms of the agreement including the settlement terms. Tell
us
how you accounted for this transaction and your consideration of
EITF
99-7 and EITF 00-19.

Item 4. Controls and Procedures
4. You disclose that your disclosure controls and procedures "were
appropriate" at July 3, 2005. It does not appear that your
certifying officers have reached a conclusion that your disclosure
controls and procedures are effective. Supplementally, confirm,
if
true, the conclusions of management that the disclosures controls
and
procedures are effective.

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 submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T. You
may wish to provide us with marked copies of any amendment to
expedite our review. Please furnish a cover letter with any
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 any amendment and 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
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 Melissa Rocha at (202) 551-3854 or me at
(202)
551-3689 if you have questions regarding comments on the financial
statements and related matters.


Sincerely,


John Hartz
Senior Assistant Chief Accountant
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Raymond J. Seabrook
Ball Corporation
November 22, 2005
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