SecProbe.io

June 3, 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 reviewed your responses dated April 28 and May 6, 2011 to our March 31, 2011
letter and have the following comments.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provid e the requested response.  Please furnish us a
letter on EDGAR under the form 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.

Results of Operations

Research and Development Programs, page 38

1. Refer to your response to comment two.  Please address the following by providing us
proposed disclosure to be include d in future periodic reports:
• The amount of R&D expense by segment, and the amount not allocated to a
segment and what that amount represents;
• A description of the R&D process by segment similar to what you provided in
your response;
• How you manage the research and development expenses (i.e. on a portfolio basis
to achieve a targeted spend);
• That you do not regularly accumulate research and development expenses for a
particular therapeutic area or development phase or ma ke management decisions
based on this data; and
• The month and the year that you entered th e late phase for thos e projects that you
disclose in late phase development.

Mr. Miles White
Abbott Laboratories
June 3, 2011
 Page 2

We encourage you to propose any additional di sclosure that you believe is necessary
to describe limitations necessary to pr ovide further context to the disclosures
requested above.

2. Refer to your response to comment two. As pr eviously requested, provide us information
regarding the remaining term of patents for each late stage project you disclose. If you do
not know or cannot estimate the remaining patent  life for a particular patent(s) associated
with a project(s), please te ll us the specific facts and circumstances governing this
limitation.
3. Please refer to page 39 and 40 and provide us pr oposed disclosure to be included in future
periodic reports that explains whethe r Medical Optics and Molecular and Core
Laboratory Diagnostics are pa rt of the Diagnostics segment and to which segment
Diabetes Care belongs.

Note 5- Taxes on Earnings, page 69

4. We acknowledge your response to prior commen t seven.  Since your annual accruals for
uncertain tax positions appear to exceed the five percent threshold in Rule 4-08(h) of
Regulation S-X, please provide us  proposed disclosure to be included in future periodic
reports showing the amount and nature of this  reconciling item of your statutory income
tax rate to your effective tax rate.
Schedule II  – Valuation and Qualifying Accounts, page 95

5. We acknowledge your response to prior commen t 5. Please provide proposed disclosure
to be included in future periodic reports that explains your charge-off policy, provides the
amount of accounts receivable past due ove r one year as of the end of each period
presented, the reason that amounts charged-off over the past several years have been so
small relative to the balance of the allowance for doubtful accounts, and why the
recorded balance for the allowance for doubt ful accounts is not excessive in view of
amounts past due and charged-off.    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