SecProbe.io

April 18, 2012

Via E-mail
Mr. Thomas C. Freyman  Executive Vice President, Finan ce and Chief Financial Officer
Abbott Laboratories  100 Abbott Park Road Abbott Park, Illinois 60064-6400
Re: Abbott Laboratories
Form 10-K for the Fiscal Year Ended December 31, 2011
Filed February 21, 2012
Form 8-K Dated January 25, 2012
Filed January 25, 2012
File No. 001-02189

Dear Mr. Freyman:

We have reviewed your filings and have th e following comments.  In our comments, we
ask you to provide us with information so  we may better underst and 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 filings.
Form 10-K for the Fiscal Year Ended December 31, 2011

Risk Factors
“Other factors can have a material adverse effe ct on Abbott's future prof itability and financial
condition,” page 14

1. You disclose that one of many factors that can affect your profitability and financial
condition are difficulties relate d to your information techno logy systems, including any
significant breakdown, invasion, destruction, loss of data privacy, or interruption of these
systems. Please tell us whether you have  experienced any si gnificant breakdown,
invasion, destruction, loss of data privacy, or interruption of  these systems in the past and
management’s view of the potential impact  of any such attacks on your operations,
expenses and risks.   Please refer to the Division of Corporation Finance’s Disclosure

Mr. Thomas C. Freyman
Abbott Laboratories
April 18, 2012
  Page 2

 Guidance Topic No. 2 at http://www.sec.gov/divisions/c orpfin/guidance/cfguidance-
topic2.htm  for additional information.

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Legislative Issues, page 50

2. Although you disclose the aspects of health care reform legislation that affect the
company, you do not quantify its impact on your financial statements.   In this regard,
please provide us proposed revised disclosure to be included in future periodic reports
indicating the amount of the redu ction to revenues for the in creased Medicaid rebate in
2011 and 2010 and for additional rebate associated with the Medicare Part D “donut hole” in 2011.   Also, include in your proposed  revised disclosure the amount of the
branded prescription drug fee you recorded in your statement of earnings in 2011, in
which line item it is classified therein and hi ghlight that this fee is not tax deductible.
Finally, if you believe that the expected effect s of health care refo rm legislation in 2012
and beyond will be materially different than th e 2011 trends, include the expected effects
in the proposed revised disclosure.
 Notes to Consolidated Financial Statements

Note 1 – Summary of Significant Accounting Policies
Concentration of risk and guarantees, page 60

3. On page 48 you disclose that your outstand ing net governmental trade receivables in
Greece, Portugal, Italy and Spain totaled $1.73 billion, $1.50 billion, and $1.59 billion at
December 31, 2011, 2010, and 2009, respectively.  Y ou also disclose that a significant
amount of these receivables are with government  health systems and state that given the
economic conditions and sovereign debt issues in these countries, the time it takes to collect outstanding receivables  increased in 2011 and that  at December 31, 2011 27% of
these receivables were past due for over a year.  Please provide us proposed revised
disclosure to be incl uded in future periodi c reports that presents  a breakdown, by country,
segregated between sovereign and any non-sove reign exposures of your trade receivables
gross and net of allowances. In addition, plea se provide disclosure on hedges, including
derivatives such as credit default swaps th at you may use to mitigate risk.  Incorporate
additional risk management disclosures whic h provide investors with insight into how
management is monitoring and/or mitigating exposures.  In addition, please tell us the payment terms for these receivables, the agi ng of these receivables and provide us your
analysis supporting why the extended payment pa ttern does not negate your assertion that
the sales price is fixed or determinable or that collectibility is reasonably assured.
 Note 4 – Post-employment benefits. Page 69

4. Please provide us proposed revised disclosure to be included in future periodic reports
that describes the transaction that resulte d in the $776 million settlement presented in
your tabular disclosure or direct  us to existing disclosures. Se parately reference for us the
authoritative literature you rely upon to support settlement accounting.

Mr. Thomas C. Freyman
Abbott Laboratories
April 18, 2012
  Page 3

 Note 5 – Taxes on earnings, page 74

5. For U.S. income tax purposes, you concluded th at the new Puerto Ri can excise tax is
creditable for U.S. income tax purposes.  It is apparent from your rate reconciliation on
page 75 that your benefit of lower foreign tax rates and tax exemptions increased 3.5
percentage points or $182 million from 2010 to 2011.  To the extent that this excise tax is
a material component of this increase, please pr ovide us proposed revised disclosure to be
included in future filings that quantifies the am ount of  theU.S. income tax benefit. Please
also provide us with your anal ysis that supports y our conclusion that the excise tax is
creditable from a US foreign tax credit pers pective and the exclusion or inclusion, as
applicable, in your unrec ognized tax benefit.

6. On page 38 you disclose that you record the new Puerto Rican excise tax in cost of
products sold.  Please provide us proposed revi sed disclosure to be included in MD&A of
future filings indicating the amount of exci se tax included in cost of goods sold and
whether the tax is levied on a gross basis or on a measure of income.  Please also provide
us proposed revised disclosure to  be included in future period ic reports to clarify whether
you capitalize the Puerto Rican excise tax incu rred as an inventoriable cost for financial
reporting purposes. To the extent that you cap italize this excise tax in inventory for
financial statement purposes, please confirm th at you defer the U.S. tax benefit associated
with the portion of the excise tax capitali zed in inventory or reference for us the
authoritative literature you rely upon to support your accounting.

Form 8-K filed January 25, 2012
Exhibit 99.1

7. It appears that you are giving undue prominence to non-GAAP measures in the
introductory highlights discussions  of your earnings releases.  As an example, in the third
bullet on the first page of this release, you discuss adjusted gross margin ratio without
balancing that discussion with  the appropriate GAAP measure.   As a second example, in
the fifth bullet on the first page of your th ird quarter 2011 earnings release, you provide
guidance for your non-GAAP earnings-per-sha re for 2011 without balancing that
guidance with the appropriate GAAP measur e.  Please provide us proposed revised
disclosure to be incl uded in future earni ngs releases that bala nces discussion of non-
GAAP measures with their most comparable GAAP measures.  Please see Instruction 2
to Item 2.02 of Form 8-K which indicates that  the provisions of Item  10(e)(1)(i) apply to
these public disclosures.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filings to be certain that the filings incl ude the information the Secu rities 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:

Mr. Thomas C. Freyman
Abbott Laboratories
April 18, 2012
  Page 4

  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.

Please contact Ibolya Ignat, Staff Account ant, at (202) 551-3656 or Mark Brunhofer,
Accounting Reviewer, at (202) 551- 3638 if you have questions regarding the processing of your
response as well as any questions regarding co mments on the financial statements and related
matters.  You may contact Laura Crotty, Staff Attorney, at (202) 551-3563  or Jennifer Riegel,
Special Counsel, at (202) 551-3575 w ith questions on any of the othe r comments.  In this regard,
do not hesitate to contact me at (202) 551-3679.

Sincerely,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant