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Correspondence

 February 8, 2010

 Rufus Decker, Accounting Branch Chief

 Division of Corporation Finance

 United States Securities and Exchange Commission

 100 F Street, N.E., Mail Stop 4631

 Washington, D.C. 20549-4631

Re:

Cabot Corporation

File No. 001-05667

 Dear Mr. Decker:

 This letter is being submitted in response to the Staff’s comment letter of January 25, 2010 in respect of Cabot Corporation’s Form 10-K for the fiscal year ended September 30, 2009.
For ease of reference, we have restated the Staff’s comments before our responses below.

 Item 1 – Business, page 3

 Research and Development, page 11

1.
In future filings please include a cross-reference here to your discussion on page 39 regarding your Research and Technical Expenses.

Cabot Response:

 In future 10-K
filings, we will include a cross-reference to our discussion set forth in the Results of Operations section of the MD&A regarding our Research and Technical Expenses in substantially the following form:

 “Further discussion of our research and technical expenses incurred in each of the fiscal years ended September 30, 20XX, 20XX and
20XX appears in Management’s Discussion and Analysis of Financial Condition and Results of Operations in Item 7.”

 Legal Proceedings, page 21

 Environmental Proceedings, page 21

2.
We note your April 11, 2008 response to comment three of our letter dated March 28, 2008. We further note that at the end of the fourth paragraph you
continue to disclose that the claims relative to Cabot are without merit without explaining the basis of such belief. Please advise or otherwise in future filings comply with our prior comment three in full.

 Cabot Response:

 We acknowledge both
your comment and our previous response to the Staff. This was an oversight on our part. In future filings, if we include a discussion of the environmental-related lawsuits in Campana, Argentina, we confirm that we will delete language stating that
the claims relative to Cabot are without merit unless we include an explanation of the basis for our belief. We will continue to re-assess the materiality of these proceedings to determine whether a discussion of these proceedings in future filings
is necessary.

3.
In future filings please ensure your disclosure in this section complies with Item 103 of Regulation S-K, including disclosure about the name of the court or
agency in which a proceeding is pending, the date instituted, the parties thereto, a description of the factual basis alleged to underlie the proceeding and the relief sought. Please refer in particular to instruction 2 of Item 103 of
Regulation S-K.

 Cabot Response:

 In future filings we will ensure that our disclosure in this section complies with Item 103 of Regulation S-K, including disclosure about the name of the court or agency in which a proceeding is
pending, the date instituted, the parties thereto, a description of the factual basis alleged to underlie the proceeding and the relief sought.

 Respirator Liabilities, page 22

4.
We note your proposed disclosure in response to comment four of our letter dated March 28, 2008. We are unable to locate disclosure regarding your total cash
payments with respect to the Aearo-related liabilities, as indicated at the end of your proposed disclosure. Please advise, or otherwise, in future filings ensure that your revised disclosure is responsive to our prior comment.

 Cabot Response:

 We acknowledge our previous response to the Staff related to this matter. However, based upon our understanding of the requirements of Item 103 of Regulation S-K, we concluded that disclosure of cash
payments made by the Company in connection with respirator claims was more appropriate within Note T - Commitments and Contingencies. Accordingly, Note T - Commitments and Contingencies, of our 10-K, on page 98, contains the following disclosure

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regarding our annual cash payments for respirator claims: “Cash payments were $2 million, $2 million and $1 million during fiscal 2009, 2008 and 2007, respectively, related to this
liability.” This disclosure also includes a discussion of the Aearo payment arrangement. Nonetheless, in future filings, we will include disclosure regarding our annual cash payments with respect to respirator claims in both the Commitments and
Contingencies note to our consolidated financial statements and in the description of this matter in the legal proceedings section of our 10-K filings, to the extent such information continues to be appropriate.

 Item 7 – Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 29

 Critical Accounting Policies, page 29

 Goodwill and Other Intangible Assets and Valuation of Long-Lived Assets, page 31

5.
In the interest of providing readers with a better insight into management’s judgments in accounting for goodwill, please disclose the following in future
filings:

•

 The reporting unit level at which you test goodwill for impairment and your basis for that determination;

•

 How you weight each of the methods used to value goodwill, including the basis for that weighting;

•

 How the methodologies used for valuing goodwill in the current year have changed since the prior year; and

•

 To the extent that any of your reporting units have estimated fair values that are not substantially in excess of the carrying value and to
the extent that goodwill for these reporting units, in the aggregate or individually, if impaired, could materially impact your operating results, please provide the following disclosures for each of these reporting units in future filings:

a.
Identify the reporting unit;

b.
The percentage by which fair value exceeds the carrying value as of the most recent step one test;

c.
The amount of goodwill;

d.
A description of the assumptions that drive the estimated fair value;

e.
A discussion of the uncertainty associated with the key assumptions. For example, to the extent that you have included assumptions in your discounted cash flow model
that materially deviates from your historical results, please include a discussion of these assumptions; and

f.
A discussion of any potential events and/or circumstances that could have a negative effect to the estimated fair value.

 If you have determined that the estimated fair value substantially exceeds the carrying value for all of your reporting units, please
disclose this determination. Please also provide the above disclosures, as applicable, for any long-lived assets or asset groups for which you have determined that undiscounted cash flows is not substantially in excess of the carrying value and to
the extent that the asset amounts, in the aggregate or individually, could materially impact your operating results or total shareholder’s equity. Please refer to Item 303 of Regulation S-K and Sections 216 and 501.14 of the SEC’s
Codification of Financial Reporting Policies for guidance. Please show us in your supplemental response what the revisions will look like.

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 Cabot Response:

 In response to your request, in future filings the Company will enhance its disclosures regarding the results of its latest annual goodwill impairment test as well as provide greater discussion of the
judgments and considerations made by management in performing the impairment tests relating to both goodwill and other long-lived assets. In addition, to the extent the Company has a situation where long-lived assets or reporting units have
estimated fair values that are not substantially in excess of the carrying value, and the potential impairment could materially impact our operating results, we will disclose additional information regarding the long-lived assets or reporting
unit(s) affected substantially in accordance with the information identified in your comment above.

 We intend to include in our 10-Q for the
quarter ended December 31, 2009 our enhanced disclosure relating to this matter, substantially as follows:

 “Goodwill and Long-Lived Assets

 Goodwill is comprised of the cost of business acquisitions in excess of
the fair value assigned to the net tangible and identifiable intangible assets acquired. Goodwill is not amortized but is reviewed for impairment annually, or when events or changes in the business environment indicate that the carrying value of the
reporting unit may exceed its fair value. The annual review is performed as of the period ending March 31 of each year.

 For the reporting units that carry goodwill balances, our impairment test consists of a comparison of each reporting unit’s carrying value to its estimated fair value. A reporting unit, for the purpose of the impairment test, is at or
one level below the operating segment level. The operating segment is presented in accordance with the FASB’s authoritative guidance on segment disclosures. We have five reporting segments, and six reporting units for the impairment review. Our
six reporting units are Rubber Blacks, Performance Products, Supermetals, Fumed Metal Oxides, Specialty Fluids, and New Business. The estimated fair value of a reporting unit is primarily based on discounted estimated future cash flows, and
secondarily we validate this model by considering other factors such as the fair value of comparable companies to our reporting units, and a reconciliation of the fair value of all our reporting units to our overall market capitalization. The
assumptions used to estimate the discounted cash flows are based on our best estimates about selling prices, production and sales volumes, costs, future growth rates, capital expenditures and market conditions over an estimate of the remaining
operating period at the reporting unit level. The discount rate is based on the weighted average cost of capital that is determined by evaluating the risk free rate of return, cost of debt, and expected equity premiums. If an impairment exists, a
loss is recorded to write-

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down the value of goodwill to its implied fair value. Our goodwill impairment testing methodologies have not changed since the prior year’s test. As a result of the test completed for
March 31, 2009, the estimated fair value substantially exceeded the carrying value of our reporting units.

 As of
December 31, 2009, our goodwill balance is allocated between two reporting units: Rubber Blacks, $XX million, and Fumed Metal Oxides, $XX million. There have been no goodwill impairment charges during the periods presented in these financial
statements.

 Our long-lived assets primarily include property, plant, equipment, long-term investments and assets held for
rent. We review the carrying values of long-lived assets for impairment whenever events or changes in business circumstances indicate that the carrying amount of an asset may not be recoverable. Such circumstances would include, but are not limited
to, a significant decrease in the market price of the long-lived asset, a significant adverse change in the way the asset is being used, a decline in the physical condition of the asset or a history of operating or cash flow losses associated with
the use of the asset.

 To test for impairment of assets we generally use a probability-weighted estimate of the future
undiscounted net cash flows of the assets or asset grouping over the remaining life of the asset to determine if the asset is recoverable. If we determine that the asset is not recoverable, we determine if there is a potential impairment loss by
calculating the fair value of the asset using a probability-weighted discounted estimate of future cash flows. The discount rate is based on the weighted average cost of capital that is determined by evaluating the risk free rate of return, cost of
debt, and expected equity premiums. To the extent the carrying value exceeds the fair value of the asset or asset group, an impairment loss is recognized in the statement of operations in that period. During the first quarter of fiscal 2010, a $X
million charge relating to the impairment of long-lived assets was recognized in the consolidated statement of operations.”

 Cash
Flows and Liquidity, page 46

6.
We note your credit facility agreement, which expires on August 3, 2010, contains various affirmative, negative and financial covenants, among other
restrictions. We further note that you intend to replace the credit facility when it expires. In future filings, please ensure that you clearly disclose the specific terms of any material debt covenants and whether you were in compliance with the
covenants as of the reporting date. In addition, if it is reasonably likely that you will not be in compliance with any of your material debt covenants, please disclose the required ratios/amounts as well as the actual ratios/amounts as of each
reporting date. This will allow readers to understand how much cushion there is between the required ratios/amounts and the actual ratios/amounts. Please also consider showing the specific computations used to arrive at the actual ratios/amounts
with corresponding reconciliations to US GAAP amounts, if necessary. See Sections I.D and IV.C of the SEC Interpretative Release NO. 33-8350. Please show us in your supplemental response what the revisions will look like.

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 Cabot Response:

 There are two material financial covenants in our revolving credit facility, subsidiary debt to total capitalization and total debt to total capitalization, that limit the additional debt we may incur.
The credit facility also contains an interest coverage covenant that becomes applicable only if Cabot’s credit rating is downgraded.

 For
the material covenants, we have a considerable cushion between the covenant limits and our actual ratios. In the past three years, the closest we have come to the subsidiary debt to total capitalization covenant limit was an actual percentage of 17%
versus a limit of 25%. For the same three year period, the closest we have come to the total debt to total capitalization covenant was an actual percentage of 39% versus a limit of 60%. Additionally, we continually monitor the risk that Cabot’s
credit rating may be downgraded by staying in regular contact with the rating agencies and monitoring our forecasted results. Our credit rating has been at BBB+/Baa1 for over 20 years and we are comfortable that the interest coverage covenant is not
at risk of being applied.

 In future filings, beginning with our 10-Q for the quarter ended December 31, 2009, we will disclose the
specific terms of our material debt covenants. The description of the material covenants in our current revolving credit facility will be as follows:

 “The credit facility contains various affirmative, negative and financial covenants which are customary for financings of this type, including limitations on our total debt to total capitalization
ratio and our total amount of subsidiary debt to total capitalization. The credit facility also contains an interest coverage covenant that becomes applicable only if Cabot’s credit rating is downgraded. As of XX, we were in compliance with all
of the covenants.”

 Additionally, if in the future it is reasonably likely that we will not be in compliance with any of our material
debt covenants, we will disclose in future filings the limits and actual amounts of these covenants along with any other required disclosures.

 Note S – Income Taxes

7.
Given your disclosure on page 92 that you have recognized losses from continuing operations in the U.S. for each of the three years ended September 30, 2009,
please enhance your disclosure in future filings to discuss the nature of the U.S deferred assets which have not been offset by valuation allowances and how you determined that these would be realized. In this regards, please address the following:

•

 Please expand your discussion of the nature of the positive and negative evidence that you considered, how that evidence was weighted , and
how that evidence