Company Name: Wm. WRIGLEY Jr. Company
Public Availability Date: October 22, 2004

Wm.WRIGLEY Jr. Company
WRIGLEY BUILDING
410 N. MICHIGAN AVENUE
CHICAGO, ILLINOIS 60611

Telephone: 644-2121
Area Code 312

October 22, 2004

Securities and Exchange Commission
Division of Corporation Finance
Office of the Chief Counsel
450 Fifth Street, N.W.
Washington, D.C. 20549

RE: Wm. Wrigley Jr. Company Omission of
Stockholder Proposal Pursuant to Rule 14a-8

Ladies and Gentlemen:

In accordance with Rule 14a-8(j) under the Securities Exchange Act of 1934, as amended, we hereby enclose six copies of the following:

1. A letter dated August 24, 2004 from Robert D. Morse (the "Proponent"), the beneficial owner of at least $2,000 in market value of voting securities of Wm. Wrigley Jr. Company (the "Company"), including the Proponent's proposal for action at the Company's forthcoming annual meeting and the statement of the Proponent in support thereof (collectively, the "Proposal").

2. This statement setting forth the reason why the Proposal may properly be omitted from the Company's proxy statement (the "Proxy Statement") for the 2005 annual meeting (the "Annual Meeting") of stockholders pursuant to Rule 14a-8(i)(12).

We wish to inform you (and, by copy of this letter, the Proponent) of the intended omission and to explain the reasons for the Company's position.

I. The Proposal

The Proponent's Proposal seeks the following changes to the Company's form of proxy:

Return the word "Against" to all voting cards for the Year 2005.

Wm. WRIGLEY Jr. Company

Division of Corporation Finance
October 22, 2004
Page 2

The full text of the Proposal is set forth in the letter from the Proponent attached hereto as Exhibit A.

II. Summary

As discussed more fully below, the Company believes that it may properly omit the Proposal from the Company's Proxy Statement pursuant to Rule 14a-8(i)(12)(i) as the Proposal deals with substantially the same subject matter as a prior proposal that did not receive the requisite percentage of votes cast when submitted.

III. The Proposal May be Omitted Pursuant to Rule 14a-8(i)(12)(i) Because It Deals with the Same Subject Matter as a Prior Proposal that Did Not Receive the Requisite Percentage of Votes Cast When Submitted

Rule 14a-8(i)(12)(i) permits the exclusion of stockholder proposals dealing with "substantially the same subject matter" as another proposal that was previously included in the company's proxy materials within the preceding five calendar years if the proposal was submitted at one meeting during those preceding five calendar years and received less that 3% of the total votes cast. Stockholder proposals that meet the exclusion criteria of Rule 14a-8(i)(12)(i) may be excluded from a company's proxy materials for any meeting held within three calendar years of the time the proposal was last included in the company's proxy materials.

Therefore, the Proponent's Proposal will be excludable if it (1) deals with substantially the same subject matter as a previous proposal; (2) such previous proposal was included in the Company's proxy materials within the last five years; (3) such previous proposal received less than 3% of the vote, and (4) the Company's Annual Meeting is to be held within three calendar years of the vote on the previous proposal. We believe that each of these four requirements are satisfied in this case.

First, the Proponent submitted a proposal (the "2002 Proposal"), a copy of which is attached as Exhibit B, for inclusion in the Company's proxy materials in conjunction with the Company's 2002 annual meeting (the "2002 Meeting"). Since the 2002 Proposal is identical to the Proposal as to actions requested to be taken, the Proposal clearly deals with "substantially the same subject matter" as the 2002 Proposal. The only differences between the Proposal and the 2002 Proposal are slight variations in the wording of the Proponent's statements supporting the Proposal.

Second, the 2002 Proposal was included in the Company's 2002 proxy materials as Proposal 9, a copy of which is attached as Exhibit C. Since the Company's 2002 proxy materials were dated February 5, 2002, the 2002 Proposal

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Division of Corporation Finance
October 22, 2004
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was included in the Company's proxy materials within the preceding five calendar years.

Third, the 2002 Proposal received only 7,092,311 votes out of 520,686,164 votes cast, or 1.362% of the votes cast on the matter, at the 2002 Meeting. Thus, the third requirement of Rule 14a-8(i)(12)(i), that the previous proposal had received less than 3% of the vote, is satisfied.

Fourth, the 2002 Proposal was submitted to the Company's stockholders in the 2002 proxy materials for the 2002 Meeting held on March 5, 2002. Since the 2005 Annual Meeting is scheduled to take place on March 8, 2005, the 2005 Annual Meeting falls within the three calendar year window of Rule 14a- 8(i)(1 2).

Based on the foregoing, we believe that the Proposal may be excluded from the Company's proxy materials for any meeting held within three calendar years of March 5, 2002, including the 2005 Proxy Statement for the 2005 Annual Meeting.

IV. Conclusion

Based on the foregoing, the Company believes the Proposal may be omitted in its entirety from the Company's Proxy Statement for the 2005 Annual Meeting. The Company seeks a determination by the staff of the Division of Corporation Finance that it will not recommend enforcement action to the Commission if the Company omits the Proposal from its proxy materials. If you have any questions or need additional information, please contact the undersigned at (312) 644-2121.

Sincerely,

Wm. Wrigley Jr. Company

By:
Name: Howard Malovany
Title: Vice President, Secretary and
General Counsel

cc: Robert D. Morse