SecProbe.io

July 28, 2010
 Mr. Thomas C. Freyman Executive Vice President, Finance and Chief Financial Officer
Abbott Laboratories
100 Abbott Park Road
Abbott Park, IL 60064-6400

Re: Abbott Laboratories
   Form 10-Q for the Period Ended March 31, 2010
   Filed May 4, 2010
   File Number:  001-02189

Dear Mr. Freyman:
 We have limited our review of your filing to the issue we have addressed in our
comment.  In our comment, we ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  Where the comment requests you to revise disclosure, the in formation you provide should show us what the
revised disclosure will look like and identify th e annual or quarterly filing, as applicable, in
which you intend to first include it.  If you do not believe our comme nt applies to your facts and
circumstances, please tell us why in your res ponse.  Please furnish us a letter on EDGAR under
the form type label CORRESP that keys your response to our comment.
 After reviewing the information you provide in  response to this comment, we may have
additional comments and/or requ est that you amend your filing.
 1. A July 20, 2009 Wall Street Journal Article titl ed “Drug Makers Criticized for Co-Pay
Subsidies” mentions the company among others as providing these “co-pay subsidies.”  We
are unable to find any disclosure of them in your filing.  Please revise your disclosure to
include a description, dollar amount for each pe riod presented and your accounting treatment
for these arrangements.  In addition, it appear s that you participate in  patient assistance
programs.  Please revise your disclosure to include a description, the dollar amount for each
period presented and your accounting treatment for these programs.

Thomas C. Freyman
Abbott Laboratories
July 28, 2010
Page 2

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comment, please provide a written statement from the company
acknowledging that:

• the company is responsible for the adequacy an d accuracy of the disclo sure in the filings;
• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filings; and
• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Tabatha Akin s, Staff Accountant at (202)  551-3658 or me at (202) 551-
3679 with any questions.
Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant