March 30, 2005

Via U.S. Mail

Roger K. Deromedi
Chief Executive Officer
Kraft Foods Inc.
Three Lakes Drive,
Northfield, Illinois 60093

RE:		Kraft Foods Inc.
      Form 10-K for the fiscal year ended December 31, 2004
		File No. 1-16483

Dear Mr. Deromedi:

      We have limited our review of your Form 10-K 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 10-K.  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 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 -

We note that on page 11 of your 10-K you state: "Revenue generated
from operations or sales to the third-party distributors in the
Middle East was approximately $250 million in 2004, representing
3.3%
of the net revenue of the Europe, Middle East and Africa segment.
In
addition, in 2004, the Company entered into agreements with third
parties for the resale of the Company`s products into Iraq, Libya
and
Syria."

In light of the fact that Syria and Libya have been identified by
the
U.S. State Department as state sponsors of terrorism; Syria is
subject to economic sanctions administered by the U.S. Treasury
Department`s Office of Foreign Assets Control; and Libya was until
recently subject to economic sanctions, please describe for us the
extent of the resale  activity with respect to your products in
Syria
and Libya, including the dollar amount of products you sold for
resale into those countries and, if known, the dollar amount of
resales; the materiality to the Company of the resale of Company
products in Syria and Libya; and your view as to whether the fact
that your products are sold in Syria and Libya pursuant to your
agreements with third parties constitutes a material investment
risk
for your security holders.  Additionally, please describe for us
the
extent and nature of the resale of Company products into Iraq
prior
to the time that country was no longer subject to U.S. economic
sanction or identified as a state sponsor of terrorism.  We may
have
further comment.

In preparing your response please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of all factors, including the
potential
impact of corporate activities upon a company`s reputation and
share
value, that a reasonable investor would deem important in making
an
investment decision.


Closing

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 942-7896 if you have any questions about the comment or
our
review.  You may also contact me at (202) 942-7817.


								Sincerely,



								Cecilia D. Blye, Chief
								Office of Global Security
Risk



cc: 	Roger Schwall
		Assistant Director
		Division of Corporation Finance
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Roger K. Deromedi
Kraft Foods Inc.
March 30, 2005
Page 1









UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0507

         DIVISION OF
CORPORATION FINANCE