SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

Mail Stop 4631
June 24, 2009

Via U.S. mail and facsimile

Mr. James B. Flaws Vice Chairman & Chie f Financial Officer
Corning Incorporated One Riverfront Plaza Corning, New York 14831
 RE: Form 10-K for the fiscal year ended December 31, 2008
  Form 10-Q for the pe riod ended March 31, 2009
   File No. 1-3247
  Dear Mr. Flaws:    We have reviewed your response letter dated June 23, 2009 and have the following additional comments.  If you disagree with our comment, we will consider your explanation as to why our comment is inapplicable or a re vision is unnecessary.
Please be as detailed as nece ssary in your explanation.
  Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2008

General

1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like.  These revisions should be included in your future filings.

Mr. James B. Flaws
June 24, 2009
Page 2 of 3   Critical Accounting Estimates, page 39

 Impairment of Assets Held for Use, page 39

 2. Your response to comment 4 in your lett er dated May 22, 2009 indicates that these
precious metals are tested for impairment as part of the appropriate asset grouping
under SFAS 144 which requires you to assess th e recoverability of the carrying value
of long-lived assets when an event of impairment occurs.  Your response to comment 3 in your letter dated May 22, 2009 also provi des additional disclosu res that will be
provided in future filings regarding your testing for impairment of assets held for use, which includes precious metals  with indefinite useful lives .  Given the significance of
the precious metals in comparison to  your total property, please expand your
disclosures to clearly state your consideration of these precious metals in your testing of the appropriate assets grouping for im pairment under SFAS 144.  Specifically, it
should be clear what consider ation is given to these prec ious metals in determining
whether an event or circumstance may be i ndicative of impairment as well as what
consideration is given to these precious meta ls in your forecast of the expected future
net cash flows in arriving at the estimated fair value of the related asset groupings.
Your disclosures should include the following:
• We note that one of the events and circumstances which may be indicative of
impairments includes a significant decrease in the market price of an asset.  Please
disclose the types of precious metals you have recorded with indefinite useful
lives as well as whether you consider the market price of these metals in your
impairment assessment; and
• You state that the fair valu e of long-lived assets is determined using an “income
approach” that starts with the forecast of  all the expected future cash flows.
Please disclose what consideration you give to the precious meta ls in arriving at
the estimated fair value of your corres ponding asset groups.  You should discuss
any significant estimates and assumptions  you make regarding these metals in
your estimated fair value, including any assumptions regarding the length of time
they will be used or the poten tial sale of the metals.

Financial Statements

Notes to the Financial Statements

Note 1.  Summary of Significant Accounting Policies

Property, Net of Accumula ted Depreciation, page 62
 3. You state that manufacturing equipment includes certain components of production equipment that are coated with or constructe d of precious metals and that these metals
have an indefinite useful life because they wi ll be returned to their elemental state and
reused or sold.  Please help us furthe r understand how you determined that it is

Mr. James B. Flaws
June 24, 2009 Page 3 of 3
appropriate to account for these precious metals  as assets with indefinite useful lives
rather than part of the salvage value of your production equipment.  In this regard we note that depreciation should be based on the cost of the asset reduced by its
estimated salvage value, with  the salvage value based on price levels in effect when
the asset is acquired and then periodica lly reviewed and revised to recognize
downward changes in value.  In addition, based on the nature of the precious metals, please help us understand how there is no loss in value as these meta ls are used in the
manufacturing process.
 4. Please tell us supplementally whether ther e have been any instances in which you
have sold these precious meta ls.  If so, please tell us when the metals were sold as
well as the corresponding sales prices and carry ing values of the metals sold.  Please
also tell us whether you have reused these precious metals in the past.  If so, please tell when they were reused in new production equipment and the corresponding
carrying values of the amounts that were reus ed.  In this regard, please tell us the
average time between the removal of the precious materials from the old production
equipment and the placement of the preci ous metals into service in the new
production equipment.

FORM 10-Q FOR THE PERI OD ENDED MARCH 31, 2009

 General

 5. Please address the above comments in your interim filings as well.

*    *    *    *
  Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response.  Please pr ovide us with a supplemental response letter
that keys your responses to our comment s and provides any requested supplemental
information.  Detailed letters greatly facilitate our review.  Please file your supplemental
response on EDGAR as a correspondence file .  Please understand that we may have
additional comments after reviewin g your responses to our comments.

If you have any questions regarding these comments, please direct them to Nudrat
Salik, Staff Accountant, at (202)  551-3692 or, in her absence, to Jeanne Baker, Assistant
Chief Accountant, at (202) 551-3691.

       S i n c e r e l y ,            R u f u s  D e c k e r         A c c o u n t i n g  B r a n c h  C h i e f