Mail Stop 0510 April 22, 2005 via U.S. mail and facsimile Mr. James E. Hurlbutt Vice President - Finance Stepan Company Edens and Winnetka Road Northfield, Illinois 60093 RE: Form 10-K for the year ended December 31, 2004 File No. 1-4462 Dear Mr. Hurlbutt: We have completed our review of your Form 10-K and related filings and have no further comments at this time. If you have any further questions regarding our review of your filings, please direct them to Scott Watkinson, Staff Accountant, at (202) 942-2926 or, in his absence, to the undersigned at (202) 942- 1774. Sincerely, Rufus Decker Accounting Branch Chief ?? ?? ?? ?? Mr. J. Gordon Beittenmiller March 25, 2005 Page 1 of 1 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-0510 DIVISION OF CORPORATION FINANCE