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Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   May 10, 2007   Mr. Thomas C. Freyman Executive Vice President, Finance and Chief Financial Officer Abbott Laboratories 100 Abbott Park Road Abbott Park, Illinois 60064-6400
Re: Abbott Laboratories
Form 10-K for the Fiscal Year Ended December 31, 2006 Filed February 23, 2007
 File No. 001-02189

Dear Mr. Freyman:

We have limited our review of your filing to those issues we have addressed in
our comments.  In our comments, we ask you to  provide us with information so we may
better understand your disclosure.  Please be as de tailed as necessary in  your explanation.
After reviewing this information, we may raise additional comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2006

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

 Critical Accounting Policies

 Sales Rebates, page 28

1. The sensitivity analysis around your product sales rebate allowance should depict
a reasonably likely change in your estimat e and not a hypothetical change.  If this
one-percentage point change analysis de picts a reasonably likely change, please

Mr. Thomas C. Freyman
Abbott Laboratories May 10, 2007 Page 2
 provide us proposed disclosure  that clarifies this fact.  If not, please revise your
analysis to depict a reasonably likely cha nge in this estimate.  In addition, please
provide us proposed disclosu re that clarifies that ad justments for prior years’
rebate accruals have not been  material to net income.

Note 11 – Business, Combinations, Technol ogy Acquisitions and Re lated Transactions,
page 69
2. We note that you recorded significant amounts of In-Proce ss Research and
Development costs for the acquisition of  KOS Pharmaceuticals Inc. and Guidant’s
vascular intervention and endovascular solu tions businesses.  Please provide us, in
disclosure-type format, the following:

a. The specific nature and fair valu e of each significant in-process
research and development project  acquired for each acquisition.

b. The completeness, complexity and uniqueness of the projects at the
acquisition date.

c. The nature, timing and estimated costs of the efforts necessary to
complete the projects, and the anticipated completion dates.

d. The valuation method that was used  to fair valu e the in-process
research and development projects acquired.

e. Disclose the significant valu ation assumptions, such as:

i. the period in which material ne t cash inflows from significant
projects are expected to commence;
ii. material anticipated changes fr om historical pricing, margins
and expense levels; and
iii. the risk adjusted discount rate applied to the project’s cash
flows.

f. In periods after the acqui sition, discuss the status of efforts to complete
the projects, and the impact of any delays on your expected investment
return, results of  operations and financial condition.

Mr. Thomas C. Freyman
Abbott Laboratories May 10, 2007 Page 3
 3. Please tell us why it is appropriate unde r GAAP to record the additional payments
made to Boston Scientific upon government approval as goodwill versus as an asset to be evaluated under FAS 2 that may or may not be capitalized.
4. Please provide us additional information regarding your accounting treatment for
the shares of Boston Scientific acquire d.  In this respect, please address the
following:
• Clarify in disclosure-type format how you classify in the financial
statements the change in fair va lue for the derivatives recorded.
• Note 2 states that the fair valu e of the Boston Scientific shares
declined by $303 million.  Please tell us why you believe the
decline should not be recorded in  income as an impairment given
you are required to sell the shares  by October 2008 and thus do not
have the ability to hold the shares until recovery.
Schedule II, Valuation and Qu alifying Accounts, page 100

5. Your Schedule II should separately de pict your allowance for doubtful accounts
and sales deductions.  Please provide us, in disclosure-type format, a revised
schedule.

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that  keys your response to our
comment and provide the request ed information.  Detailed le tters greatly facilitate our
review.  Please furnish the letter to us via EDGAR under the form type label CORRESP.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our co mments, please provide, in your letter, 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 with 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.

Mr. Thomas C. Freyman
Abbott Laboratories May 10, 2007 Page 4
 In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact Dana Hartz,  Staff Accountant, at ( 202) 551-3648 or Mary Mast,
Review Accountant, at (202) 551-3613 if you have questions regarding the comments.
Please contact me at (202) 551-3679 with any other questions.
  Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant