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CORRESP
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May 7, 2008

Mr. Jeffrey Riedler

Assistant
Director

United States Securities
and Exchange Commission

Division of Corporate
Finance

100 F Street, N.E.

Washington, D.C. 20549

Re:          Abbott Laboratories

                Form 10-K for Fiscal Year
ended December 31, 2007

                Filed February 19, 2008

                File No. 001-02189

Dear Mr. Riedler:

I
am responding to your letter of April 30, 2008.  Our response is detailed in the attachment
hereto.

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

Sincerely,

/s/ Laura J. Schumacher

Laura
J. Schumacher

LJS: jm

Attachment

Abbott
Laboratories

Form 10-K
for Fiscal Year ended December 31, 2007

Filed February 19,
2008

File No. 001-02189

Item
1. Business

International
Operations, page 8

1.              We
note your disclosure that  you market
products in approximately 130 countries through affiliates and
distributors.  In a supplemental
response, please advise us as to whether you conduct business with Sudan, Iran,
Syria, North Korea, or Cuba.

Response:

Abbott supplies its medical,
nutritional, and medical device products to Sudan, Iran, and Syria to fulfill
the humanitarian needs of the civilian population, pursuant to licenses granted
to Abbott by the United States government, where required.  Abbott does not currently conduct business
with North Korea or Cuba.

Item
15. Exhibits, Financial Statement Schedules

2.              We
note that you have described your acquisition agreement regarding Kos
Pharmaceuticals Inc., but did not file it as an exhibit.  Please file this agreement as an exhibit or
provide us with an analysis supporting your determination that the agreement is
not required to be filed pursuant to Item 601(b)(10) of Regulation
S-K.  Please note that if this agreement
was filed previously, you may amend your Form 10-K to incorporate the
previously-filed agreement by reference.

Response:

On December 15,
2006, Abbott completed its acquisition of Kos Pharmaceuticals Inc.  Abbott’s 2006 Form 10-K incorporated the
related acquisition agreements, which were originally filed as exhibits either
to a Form 8-K dated November 9, 2006 or to a Schedule TO dated November 14,
2006. After Abbott completed the Kos acquisition, it did not have any
continuing obligations to the other parties to the transaction and thus did not
consider the agreements to still be material at the time it filed its 2007 Form 10-K
and, therefore, did not again include them as exhibits.

Abbott
regards the acquisition of Kos Pharmaceuticals Inc. as occurring in the
ordinary course of its business. Abbott routinely pursues acquisitions,
technology licensing arrangements, and strategic alliances as part of its
business strategy.  Accordingly, pursuant
to Item 601(b)(10)(ii), Abbott is not required to again file the agreements as
exhibits to its 2007 Form 10-K.