Mail Stop 3-8

								March 16, 2005
By US Mail and Facsimile

Mr. Michael G. Koppel,
Executive Vice President and Chief Financial Officer
Nordstrom, Inc.
1617 Sixth Avenue
Seattle, Washington  98101

		RE:	Form 8-K filed on February 15, 2005

Dear Mr. Koppel:

	We have performed a targeted review of your filing and have
following comments.  As indicated below, we request supplemental
information from you in response to these comments.  Please be as
detailed as necessary in your response.

	Please understand that the purpose of our review process is
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
of our review.  Feel free to call us at the telephone numbers
at the end of this letter.


Form 8-K filed February 15, 2005

Correction in Lease Accounting Policy

1. Please tell us supplementally and disclose the specific nature
the correction in your lease accounting policy.  Based on your
disclosure that you recorded a charge in the fourth quarter of
relating to a correction in your lease accounting policy it
that your historical accounting for leases may not have been in
accordance with GAAP.  As a result, we would expect you to restate
your prior period financial statements unless the correction of
error is immaterial. If you are restating your historical
statements, we would expect your disclosures to indicate that the
restatement results from the correction of an error. If
is determined to be unnecessary, your disclosures should indicate
that the errors were immaterial to prior periods.  In this regard,
please provide us supplementally your quantitative and qualitative
assessment of the materiality of these errors for the fiscal years
ended January 31, 2002, 2003 and 2004 as well as your quarterly
periods ended May 1, 2004, July 31, 2004 and October 30, 2004.
Please ensure your analysis addresses fully the considerations
described in SAB 99 including the impact on income from
pretax income, net income, earnings per share, cash flows from
operating, investing, and financing activities, and the balance
line items for all periods affected.

2. Please tell us supplementally and disclose in your next filing
your discovery of this error impacted your evaluation of the
effectiveness of your disclosure controls and procedures.  Also
us and disclose whether you changed your disclosure controls and
procedures or internal controls over financial reporting as a
of your discovery of this error.

3. Please ensure your disclosures in future filings address the
material terms of and accounting for leases.  In this regard, we
there is no disclosure in your Form 10-K for the fiscal year ended
January 31, 2004 or in your subsequent Form 10-Q filings which
addresses the existence of lease incentives other than developer
reimbursements you receive as incentives to construct stores in
certain developments. You say you capitalize property, plant and
equipment for these stores during the construction period in
accordance with EITF Issue No. 97-10 and at the end of the
construction period, developer reimbursements in excess of
construction costs are recorded as deferred lease credits and
amortized as a reduction to rent expense, on a straight-line basis
over the life of the applicable lease or operating covenant.
Construction costs in excess of developer reimbursements are
as prepaid rent and amortized as rent expense on a straight-line
basis over the life of the applicable lease or operating covenant.
Please clarify your disclosure to explain how and why the guidance
EITF 97-10 is applicable to your lease transactions.  In addition,
your future disclosures should address the following, as noted in
SEC Staff letter dated February 7, 2005:

* Material lease agreements or arrangements;
* The essential provisions of material leases, including the
term, renewal periods, reasonably assured rent escalations, rent
holidays, contingent rent, rent concessions, leasehold improvement
incentives, and unusual provisions or conditions;
* The accounting policies for leases, including the treatment of
of the above components of lease agreements;
* The basis on which contingent rental payments are determined
specificity, not generality; and
* The amortization period of material leasehold improvements made
either at the inception of the lease or during the lease term, and
how the amortization period relates to the initial lease term.


	Please respond to these comments within 10 business days, or
tell us when you will provide us with a response.  Please provide
with a supplemental response letter that provides the requested
supplemental information.  Detailed letters greatly facilitate our
review.  Please file your response letter on EDGAR as a
correspondence file.  Please understand that we may have
comments after reviewing your response to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
certain that they have provided all information investors require
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
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
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
access to all information you provide to the staff of the Division
Corporation Finance in our review of your filing or in response to
our comments on your filing.
	If you have any questions regarding these comments, please
direct them to Sondra Snyder at (202) 942-1827 or, in her absence,
the undersigned at (202) 942-2905.  Any other questions regarding
disclosures issues may be directed to H. Christopher Owings at


							George F. Ohsiek, Jr.
							Branch Chief





Nordstrom, Inc.
March 16, 2005
Page 1