UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-5546 DIVISION OF CORPORATION FINANCE Mail Stop 5546 July 7, 2006 Via Facsimile (404) 515-2546 and US Mail E. Neville Isdell Chief Executive Officer The Coca Cola Company One Coca-Cola Plaza Atlanta, Georgia 30313 Re: The Coca Cola Company Form 10-K for the Fiscal Year Ended December 31, 2005 Filed February 28, 2006 Response Letter Dated May 26, 2006 File No. 1-2217 Dear Mr. Isdell: We have reviewed your response letter dated May 26, 2006 and have the following comment. Please be as detailed as necessary in your response. 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. General 1. You state in your response to prior comment two that you provide concentrates to bottlers in Iran and Sudan pursuant to an OFAC license that is renewed annually, and you have secured an export license to provide certain information and know-how to Cadbury Schweppes bottlers in Syria. You also state that two bottlers, including one in which you have a minority interest, have sold your products into Syria since 2004; that you intend to grant distribution rights for your finished products with respect to Syria to a new distribution company which will source your products from bottlers in the region; and that you have a minority ownership interest in one of the bottlers expected to participate in the new distribution company. You do not discuss OFAC or BIS licensing in connection with any of these bottling or distribution arrangements. Please explain whether you have received licenses for these arrangements, or rely on general licenses, or the arrangements are exempt from OFAC and BIS licensing requirements. Please file your response letter on EDGAR. 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: Christopher Owings Assistant Director Division of Corporation Finance Mr. E. Neville Isdell The Coca Cola Company Page 1