SecProbe.io

July 25, 2011
 Via E-mail

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 Ju ly 1, 6, and 18, 2011 to our June 3, 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. We acknowledge your response to prior commen t two and request further information to
understand your proposed disclosure particular ly your assertion that you cannot estimate
the total period of exclusivity that will be obtained if regulatory a pproval is obtained.  For
each late stage project (i.e. in Phase 3) and assuming the product got approved as of the balance sheet date, tell us:
 The remaining years of the last patent that protects the product;
 The nature of and number of years of re gulatory exclusivity available in excess of
remaining years of the patent in bullet one;
 How each year beyond the assumed balance sh eet date to get approval effects the
number of years in bull ets one and two; and
 The nature of other significant factors and how each could affect the number of
years in bullet one and two.

Mr. Miles White
Abbott Laboratories
July 27, 2011
 Page 2

 In providing the above information for each phase  3 project, it is not necessary to provide
the actual name of the produc t in your response to us.

Schedule II  – Valuation and Qualifying Accounts, page 95

2. We acknowledge your response to prior commen t five. You state that you do not have the
amount of accounts receivable past due more  than one year as of December 31, 2010 and
2009 readily available.  You also  state that due to the recent growth of international sales
your collection risks have increased.  Though your  international sales have increased in
recent years from 51% of sales in 2008 to  57% of sales in 2010, your international
revenues accounted for over 50% of your revenu es over the last three years and you have
had small bad debt write-offs.  In this regard, your allowance for doubtful accounts of
$388.6 million at December 31, 2010 significantly exceeds the highest level of accounts
receivable written-off over the last three years of $27.8 million and the average level of
write-offs over the last three years of $19.5 m illion.  Please provide us an analysis that
demonstrates why you believe that an allowan ce of almost 20 times your average level of
write-offs is reasonable and not excessive.
 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,

       / s /  J i m  B .  R o s e n b e r g

Jim B. Rosenberg Senior Assistant Chief Accountant