SecProbe.io

November 7, 2017

Via E -mail
Miles D. White
Chairman of the Board and Chief Executive 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 , 2016
  Filed February 17 , 2017
  File No. 1-02189
Dear Mr. White:
We have limited our review of your filing to your contacts with a country that has  been
identified as a state sponsor  of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   At this juncture, we are asking you to provide us with information so we may
better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your fact s and circumstances, please tell us why in your response.

After reviewing the information you provide in response to this comment, we may have
additional comments.

General

1. On your website you provide contact information for your diabetes care b usiness in Syria.
In its letter to us dated December 19, 2014, St. Jude Medical, Inc., which you acquired in
January, stated that during fiscal years 2011 and 2012 and the first quarter of 2014, it sold
medical devices into Syria.  Syria is  designated as a state sponsor  of terrorism by the
State Department and is  subject to U.S. economic sanctions and export controls.   You do
not include disclosure a bout any contacts with Syria.  Please describe to us the nature and
extent of any past, current and anti cipated contacts with Syria, whether throug h
subsidiaries, distributors, customers or other direct or indirect arrangements .  You should
describe any goods , technology and services y ou have provided into Syria, directly or
indirectly, and any agreements, arran gements or other contacts you have had with the
governments of Syria or entities it  control s.

Miles D. White
Abbott Laboratories
November 7 , 2017
Page 2

 2. Please discuss the materiality  of any contacts with Syria you describe in response to the
comment above, and whether the contacts constitute a material investmen t risk for your
security holders.   You should address materiality in quantitative terms, including the
approximate dollar amounts of any revenues, assets and liabilities associated with Syria
for the last three fiscal years and the subsequent interim perio d.  Also, address materiality
in terms of qualitative factors that a reasonable investor would deem important in making
an investment decision, including the potential impact of corporate activities upon a
company’s reputation and share value.   Various sta te and municipal governments,
universities and other investors have proposed or adopted divestment or similar initiatives
regarding investment in companies that do business with U.S. -designated state sponsors
of terrorism.   You should address the potential  impact of the investor sentiment
evidenced by such actions directed toward companies that have operations associated
with Syria.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Please contact Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202) 551 -
3470 if you have any questions about the comments or our review.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Suzanne Hayes
  Assistant Director
 Division of Corporation Finance