SecProbe.io

March  19, 2013

Via E -mail
Mr. Thomas C. Freyman
EVP, Finance & Chief Financial  Officer
Abbott Laboratories
100 Abbott Park Road
Abbott Park, IL 60064 -6400

Re:  Abbott Laboratories
 Form 10 -K for the Fiscal Year Ended December  31, 2012
Filed February  15, 2013
 File No. 001-02189

Dear Mr. Freyman :

We have limited our review to only your financial statements and related disclosures and
do not intend to expand  our review to other portions of your document.   In our comment s, we ask
you to provide 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 adv ising us when you will provide the requested re sponse.  If you do not
believe a comment  applies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the form type label CORRESP that keys your
responses to our comment s.

After reviewing the information you provide, we may have additional comments and/or
request that you amend your filing .

Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Sales, page 33
1. The table presented on page 33 shows the vascular product segment had a 7.9% decrease
in sales from the prior year as a result of a 5.2% decrease in prices, 2.3% decrease related
to exchange differences, and a 0.4% decrease due to volume. How ever, you indicate that
the decrease in 2012 vascular product sales is partially due to the winding down of
royalty and supply agreements.  The effect of these agreements would appear to affect the
volume component rather than the price component. Please p rovide proposed disclosure
to be provided in future periodic reports to discuss the reason for the decrease in pricing
related to your vascular product sales in 2012 .

Mr. Thomas C. Freyman
 Abbott Laboratories
 March  19, 2013
 Page 2

 Reports of Independent Registered Public Accounting Firm, page 88
2. Please have Deloitte & Touche LLP explain to us why their report refers to the “auditing
standards” instead of “the standards” of the PCAOB and how their report complies with
paragraph 3 of PCAOB Auditing Standard No. 1.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s all information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  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 t o our comment s, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;
 staff comment s or changes to disclosure in response to the staff comment s do not
foreclose the Commission from taking any action with respect to the filing; and
 the company may not assert the staff comment s as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

You may contact Sasha Parikh , Staff Accountant, at (202) 551 -3627 or Don Abbott ,
Review Accountant, at (202) 551 -3608 if you have questions regarding the comment s. 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