SecProbe.io

March 1 6, 2015

Via E -mail
Mr. Thomas C. Freyman
Executive  Vice President , Finance  and Chief Financial  Officer
Abbott Laboratories
100 Abbott Park Road
Abbott Park, Illinois 60064

Re: Abbott Laboratories
 Form 10-K for the Fiscal Year Ended December 31 , 2014
Filed February 27, 2015
 File No. 1-02189

Dear Mr. Freyman :

We have limited our review to only your financial statements and related disclosures and
have the following comments .  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 advising us when you will provide the requested resp onse.  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
response s to our comment s.

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

Notes to Consolidated Financial Statements
Note 1 – Summary of Significant Accounting Policies
Revenue Recognition, page 53

1. You dis close that you recognize revenue from the licensing of product rights and the
performance of research or selling activities over the periods earned.  Please tell us the
amounts of each of these streams of revenues you recognized in each of the last three
years and address the following:
 Tell us your consideration for disclosing each revenue stream separately under Item
5-03.1 of Regulation S -X;
 Tell us your consideration for disclosing the terms of any material arrangements
under which these revenues are earned; and
 To the extent these streams are material, provide us proposed revised policy
disclosure to be provided in future periodic reports that clarifies how you recognize
these revenues “over the periods earned.”

Mr. Thomas C. Freyman
Abbott Laboratories
 March 1 6, 2015
 Page 2

Note 3 – Discontinued Operations, page  57

2. Please demonstrate to us why discontinued operations classification is appropriate for the
disposal of your developed markets branded generics business.  Reference for us the
authoritative literature you rely upon to support your accounting.  In your response,
specifically tell us how this disposal meets the requirements of ASC 205 -20-45-1 in light
of the continuing cash flows associated with the transition services and supply
agreements and your ownership in Mylan N.V. under which it appears you will be able to
exert significant influence.  In addition, please provide us proposed revised disclosure to
be included in future periodic reports that provides the principal factors you used to
conclude that the expected continuing cash flows are not direct ca sh flows of the
developed markets branded generics business as required by ASC 205 -20-50-4c.

 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 th ey 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 disclosu re in response to staff comment s do not foreclose
the Commission from taking any action with respect to the filing; and
 the compa ny may not assert the staff comment s as a defense in any proceeding initiated
by the Commission or any person under the federal secur ities laws of the United States.

You may contact Mark Brunhofer, Senior Staff Accountant , at (202) 551 -3638  or Sharon
Blume, Accounting Branch Chief, at (202) 551 -3474 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