SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 4631
July 15, 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 July 7, 2009 and have the following additional comments.  If you disagree with our comment, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary.  Please
be as detailed as necessary 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
July 15, 2009
Page 2 of 4   Financial Statements

 Notes to the Financial Statements

 Note 1.  Summary of Significant Accounting Policies

 Property, Net of Accumula ted Depreciation, page 62

 2. We note your response to prior comment 3.  As previously requested, please help us
understand how you determined that it is a ppropriate to account for these precious
metals as assets with indefinite useful lives rather than as part of the salvage value of
your production equipment.  In this rega rd, specifically address the following:
• Identify the accounting litera ture that led you to determine it is appropriate for
these tangible assets to have an indefinite us eful life.  In this regard, we note that
you are currently using a shrinkage approach which result s in the recording of a
uniform expense as the precious metal is  utilized in the production process;
• Tell us what consideration you gave to including the value of these precious
metals in your estimated salvage value, with the salvage value based on price levels in effect when the asset is acqui red and then periodic ally reviewed and
revised to recognize downward changes in value, as necessary, in accordance with
the change in accounting estimate guidance of SFAS 154; and
• Please also tell us what consideratio n you gave to the guidance provided in
Section 2140.8 of the AICPA’s Technical Questions and Answers regarding the
valuing of precious metals inventory us ed in manufacturing applications.

3. Please provide us with the following a dditional information regarding the glass
melting equipment which is coated with  or constructed of precious metals:
• It appears that this glass melting equi pment consists of multiple components
including precious metals.  Please describe each of the components included in the glass melting equipment as well as the corresponding useful lives of each
component.  In order for us to unders tand the significance of each component,
please tell us the dollar amount recorded re lated to each of these components as of
December 31, 2008 and March 31, 2009 as we ll as the total do llar amount of all
components; and
• Significant components of the melting equipm ent must be rebuilt in order for the
equipment to function properly.  Please te ll us what types of costs are incurred
when the equipment is rebuilt and whethe r these costs are capitalized or expensed
as incurred.  For each of the three years ended December 31, 2008 and the three months ended March 31, 2009, please tell us the total amount of costs incurred in
rebuilding the equipment and identify the portion of this total which were
capitalized and expensed.

Mr. James B. Flaws
July 15, 2009
Page 3 of 4   4. Your response to comment 2 in your lett er dated June 15, 2009 states that you do not
believe separate disclosure provides an investor with additional meaningful information because precious metals are part of the equipment used for operations and can only be removed by stopping producti on.  You further believe that separate
disclosure may lead readers of the financ ial statements to the inaccurate conclusion
that these assets can somehow be sepa rated from the production equipment and
monetized currently.  Notwithstanding these concerns, given the si gnificance of your
precious metals, we continue to believe that you should disc lose the amount of
precious metals recorded in equipment as of the end of each period.  Additional clarifying information provided in your f iling can sufficiently convey to readers how
you utilize these metals in your production process and your inability to currently
monetize them.  In addition, a full discu ssion of your accounting for these assets
appears necessary for a reader’s full understa nding of these assets  and their impact on
your financial statements.  Please advise or  revise your disclosures accordingly.
 5. Please provide us with the following addi tional information regarding your rhodium
and platinum precious metals:
• Please quantify both by dollar and ounces the amount of rhodium and platinum
held at December 31, 2007, December 31, 2008, and March 31, 2009 and their
weighted average historical cost as of the end of each period;
• For the last fifteen years, please provide  a yearly breakdown of the amount of
rhodium and platinum purchased in ounces  and in total dollars  and the respective
average yearly cost of each precious metal; and
• Please address the significant declines in the market price of rhodium and platinum in recent years.  Your list of  events and circumstances that may be
indicative of impairment includes a signifi cant decrease in the ma rket price of an
asset.  Please clarify whether significant decreases in the market price of precious metals would be considered triggering events under SFAS 144.  If not, address why not.

*    *    *    *

  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.

Mr. James B. Flaws
July 15, 2009 Page 4 of 4
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