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[email protected]) SEOUL SHANGHAI SINGAPORE TOKYO TORONTO December 11, 2020 U.S. Securities and Exchange Commission Division of Corporation Finance Office of Chief Counsel 100 F Street, N.E. Washington, D.C. 20549 RE: Johnson & Johnson – 2021 Annual Meeting Omission of Shareholder Proposal of Oxfam America, Inc. and co-filers1 Ladies and Gentlemen: Pursuant to Rule 14a-8(j) promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), we are writing on behalf of our client, Johnson & Johnson, a New Jersey corporation, to request that the Staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) concur with Johnson & Johnson’s view that, for the reasons stated below, it may exclude the shareholder proposal and supporting statement (the “Proposal”) submitted by Oxfam America, Inc. (“Oxfam”) and co-filers from the proxy materials to be distributed by Johnson & Johnson in connection with its 2021 annual 1 The following shareholders have co-filed the Proposal: Achmea Investment Management; Benedictine Sisters of Boerne, Texas; Benedictine Sisters of Virginia, Inc.; CommonSpirit Health; Congregation of Divine Providence; Mercy Investment Services, Inc.; Monasterio De San Benito; PeaceHealth; Providence Trust; The Sisters of Charity of Saint Elizabeth; The Sisters of Providence, Mother Joseph Province; and Trinity Health.