SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 4720
         April 22, 2010   Thomas C. Freyman CFO & EVP Finance Abbott Laboratories 100 Abbott Park Road Abbott Park, Illinois 60064
 Re: Abbott Laboratories
  Form 10-K for the fiscal year ended December 31, 2009
  Filed February 19, 2010   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 to better
understand your disclosure. Where a comment requests you to revise disclosure, the
information you provide should show us what the revised disclosure will look like and
identify the filing in which you intend to firs t include it. If you disagree, we will consider
your explanation as to why our comments are inapplicable or a revision is unnecessary. After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

 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.
 General

1. We have not yet reviewed the Part III information that is included in your
definitive proxy statement.  We may ha ve further comments after reviewing
that information and we will not be able to clear our review of your filing until we
have the opportunity to reso lve any resulting comments.

Thomas C. Freyman
Abbott Laboratories April 22, 2010 Page 2
 Item 7. Management's Discussion And Analys is Of Financial Cond ition And Results Of
Operations
Financial Review, page 26

2. You incurred $2.7 billion, $2.7 billion and $2.5 billion on research and
development activities, excluding acquired in-process research and development,
in 2009, 2008 and 2007, respectively, representi ng 9%, 9% and 10% of net sales,
respectively, and 38%, 46% and 56% of  pretax earnings from continuing
operations, respectively, for these years.  However, your disclosures about your
research and development pipeline appear to be limited to general statements
regarding the therapeutic areas you are focusing on a nd that you have dedicated,
and plan to continue to dedicate, su bstantial resources to maximizing the
worldwide potential of HUMIRA .    Please expand your disclosure by referring to
the Division of Corporation Finance “C urrent Issues and Rulemaking Projects
Quarterly Update” under section VIII – I ndustry Specific Issues – Accounting and
Disclosure by Companies Engaged in Research and Development Activities.  You can find it at the following website address: http://www.sec.gov/divisions/c orpfin/cfcrq032001.htm#secviii
.

Please disclose the following information for each of your major research and
development projects:

a. The nature, objective, and current status of the project and th e extent that its
success relies on parties other than you;
b. The costs incurred during each period pr esented and to date on the project;
c. The nature, timing and estimated costs of the efforts necessary to complete the
project;
d. The anticipated completion dates;
e. The risks and uncertainties associated with completing development on
schedule, and the consequences to oper ations, financial position and liquidity
if the project is not comp leted timely; and finally
f. The period in which material net cash in flows from significant projects are
expected to commence.
 Regarding b., if you do not maintain a ny research and development costs by
project, disclose that fact and explai n why management does not maintain and
evaluate research and development costs by project.  Provide other quantitative or
qualitative disclosure that indicates th e amount of the company’s resources being
used on the project.  Regarding c. , d. and f., disclose the amount or range of estimated costs and
timing to complete the phase in process and each future phase. To the extent that

Thomas C. Freyman
Abbott Laboratories April 22, 2010 Page 3
 information is not estimable, disclose t hose facts and circumstances indicating the
uncertainties that preclude you fr om making a reasonable estimate.
 Conclusion of TAP Pharmaceutical Products In c. Joint Venture and Sale of Abbott's
Spine Business, page 33

3. You disclose that you receive paymen ts from Takeda based on specified
development, approval and commercial events being achieved with respect to products retained by Takeda and paymen ts from Takeda based on sales of
products retained by Takeda, which are reco rded as Other (income) expense, net
as earned. Please quantify the payments received and how these payments are recognized, as “as earned” is vague. Also, clarify the time period these payments
will terminate.
4. We also note that the payments you made to Takeda related to certain research
and development events not achieved on the development assets retained by Takeda ceased in 2009. Please clarify why these payments ceased and no further
payment is required which resulted in the company recognizing $797 million in other income.  In your response, please explain to us why you accrued the original
$1.1 obligation in 2008 and reference for us the authoritative literature you relied
upon to support your accounting.

* * * * *

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
comments and provides the requested information.  Detailed letters 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

Thomas C. Freyman
Abbott Laboratories April 22, 2010 Page 4
 the Commission or any person under the federa l securities laws of  the United States.

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 Sasha Pa rikh, Staff Accountant, at (202) 551-3627 or Mark
Brunhofer, Review Accountant, at (202) 551- 3638 if you have quest ions regarding the
processing of your response as well as any questions regarding comments on the financial
statements and related matters. Please contac t Nandini Acharya, Staff Attorney, at (202)
551-3495 with questions on any of the other commen ts.  In this regard, do not hesitate to
contact me at (202) 551-3679.

       S i n c e r e l y ,             J i m  B .  R o s e n b e r g         Senior Assistant Chief Accountant