SecProbe.io

March 31, 2011

Mr. Miles White
Chairman and Chief Executive Officer
Abbott Laboratories
100 Abbott Park Road
Abbott Park, Illinois 60064-6400

Re: Abbott Laboratories
Form 10-K for the Year Ended December 31, 2010
Filed February 18, 2011
File No. 001-02189

Dear Mr. White:

We have limited our review of your filing to  those issues we have addressed in our
comments.  In our comments, we ask you to pr ovide us with information so we may better
understand your disclosure.

Please respond to this letter within 10  business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe a comment applies to your facts and circ umstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the fo rm type label CORRESP that keys your
responses to our comments
 After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

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

Results of Operations
 Sales, page 33

1. In order to better understand the connec tion between your prod uct rights including
licenses and patents and the reve nues that are generated as a re sult of these rights, as well
as to assess the potential for impairment, pl ease provide us a br eak out of revenues by
product or the level disclosed in your earnings press releases, the name  or description of
the related product rights including licenses and patents, the value assigned, and the
expiration date(s) of the product ri ghts in a format to be incl uded in your future periodic
filings.

Mr. Miles White
Abbott Laboratories
March 31, 2011
 Page 2

 Research and Development Programs, page 38

2. In order to help us evaluate your disclo sure about your research and development
activities, please provide us the following information:
• The description of research and develo pment process for each of your segments
including whether an approva l is required by the FDA;
• Research and development expenses incurred during 2010 and 2009 by segment;
• For those projects that require an FDA approva l, quantify the number  of projects that
were in preclinical phase, Phase 1, Phase 2, and Phase 3 of the clinical development
and those for which a NDA was filed as of December 31, 2010;
• For each segment requiring FDA approval, th e breakout of research and development
expense incurred during 2010, if practicable, by development phase (i.e. preclinical,
phase 1, phase 2 phase 3) and by therapeutic class;
• For those late phase development projects (i.e . Phase 3 projects) listed here, indicate
the month and the year that it entered that phase;
• For those late phase development projects (i.e . Phase 3 projects) listed here, identify
the significant patents associated with the project and their expiration date; and
• Tell us about any late stage projects that are not listed here and the reason not listed.
 Financial Condition, page 43

3. The effect of exchange rate changes on cash held in foreign currencies was a reduction of
$621 million of your cash and cash equivalents in  2010 as reflected on your statement of
cash flows.  Please provide us proposed disclosu re for inclusion in fu ture periodic filings
explaining the reason for this reduction and th e expected effects, if any, on future
financial position.
 Consolidated Financial Statements

 Consolidated Statements of Cash Flows, page 51

4. Please tell us why you classified cash deposit ed in a restricted a ccount of $1.87 billion
that a district court awarded to NYU and Centoc or for patent infringement as cash used in
investing activities rather than cash used in operating activities in 2010.  Please refer to
ASC 230-10-45-17(f).
 Note 1 – Summary of Significant Accounting Policies

Accounts Receivable Valuation, page 57

5. Over the last three years you have recorded  provisions for bad debts of $188.8 million but
only written-off trade receivables of $58.6 million.  In addition, the allowance for
doubtful accounts of $388.6 million at December 31, 2010 significantly exceeds the cumulative amount of trade receivables written- off over the last three years.  Please tell
us about any specific allowances for known tr oubled accounts or other currently available

Mr. Miles White
Abbott Laboratories
March 31, 2011
 Page 3

 information used to establish the $3 88.6 million allowance for doubtful accounts at
December 31, 2010.
 Note 5 – Taxes on Earnings, page 69

6. Your foreign operations accounted for 57%, 53% and 51% of your revenues and 105%,
79% and 101% of your pre-tax income  in 2010, 2009 and 2008.  Please provide us
proposed disclosure for your MD&A to be incl uded in future period ic filings explaining
the underlying reasons for the disproportionate pre-tax income of your foreign operations
in relation to your foreign sales.  Please al so discuss in this proposed disclosure the
reasons why your effective tax rate of 19% in 2010, 20.1% in 2009 and 19.25 in 2008 is
significantly lower than the statutory rate of  35%, including the countries that account for
the majority of the lower effective tax rate.

7. You disclose benefits of lower forei gn tax rates of 19.4% in 2010, 16.4% in 2009 and
16.7% in 2008 . Please provide us proposed disclosure for your MD&A to be included in
future periodic filings that clarifies what the foreign rate differential represents in each of
the three years presented. Please also tell  us how the foreign rate differential is
determined in each fiscal year and identif y the significant components of this item.

8. You disclose that you have not provided fo r taxes on approximately $26.8 billion of other
undistributed earnings of foreign subsidiaries  at December 31, 2010 as these earnings are
reinvested indefinitely.  Pl ease provide us proposed disclosure for your MD&A to be
included in future periodic filings discussi ng the amount of cash held in your foreign
subsidiaries that is considered  reinvested indefinitely and its  expected effects on liquidity
and capital resources such as restrictions for payment of operating expenses and use to
pay $2 billion debt due in 2011, as applicable. Please refer to Item 303 (a)1 of Regulation
S-K and SEC Release 33-8350 Section IV.

Note 12 – Goodwill and Intangible Assets, page 81

9. Please provide us disclosure in the format to be provided in your future periodic filings
that indicates where in your statement of earnings you classify amortization of intangible
assets.

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 comments, please provi de a written statement from the company
acknowledging that:

• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

Mr. Miles White
Abbott Laboratories
March 31, 2011
 Page 4

 • 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 federa l securities laws of  the United States.

Please contact Kei Nakada, Staff Accountan t, at (202) 551-3659 or Gus Rodriguez,
Accounting Branch Chief, at (202) 551-3752, if you have questions regarding the comments.  In
this regard, do not hesitate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief Accountant