SecProbe.io

March 28, 2012
 Via Facsimile

Mr. James B. Flaws Vice Chairman and Chief Financial Officer Corning Incorporated One Riverfront Plaza Corning, NY  14831
RE: Corning Incorporated
Form 10-K for the Year ended December 31, 2011
Filed February 13, 2012
  File No. 1-3247

Dear Mr. Flaws:
 We have reviewed your filings and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within te n 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 facts and circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 10-K for the Year Ended December 31, 2011

 Item 15 – Exhibits, Financial Statement Schedules, page 57

 Note 6 – Income Taxes, page 80

 1. It appears that you generate a significant amount of income before income taxes from
locations outside of the United States and a si gnificant portion of your provision (benefit) for
income taxes is also composed of non-U.S. amo unts.  Please tell us wh at countries comprise
a material amount of your foreign taxes and whether you generate a disproportionate amount
of taxable income in countries  with very low tax rates.

Mr. James B. Flaws Corning Incorporated March 28, 2012 Page 2

 Note 7 – Investments, page 83

 Pittsburgh Corning Corporation (PCC), page 88

 2. You disclose that at the time PCC filed for bankruptcy protec tion, there were approximately
11,800 claims pending against you alleging various th eories of liability based on exposure to
PCC’s asbestos products.  In addition, you also disclose that you are currently involved in
approximately 9,900 other cases alleging injuri es from asbestos.  Please enhance your
disclosure to clarify whether these 9,900 other cases are th e non-PCC asbestos claims that
you have recorded $150 million for estimated asbe stos litigation liability as disclosed on
page 89.
 3. We note your disclosure that th e 9,900 other cases alleging injuri es from asbestos have been
covered by insurance without material impact to  you to date.  We also note your disclosure
that several of your insurers have commen ced litigation concerning the extent of any
insurance coverage for these claims.  Please disclose the amount of insurance payments you
have received in the past relate d to these claims.  Please also clarify your disclosure to state
whether this litigation relates to recovery of past insurance payments  or future insurance
payments.

Note 11 – Other Liabilities, page 92

 Asbestos Litigation, page 92

 4. With respect to the non-PCC asbestos claims, please tell us what consideration you gave to
disclosing the number of claims pending at each balance sheet date, the number of claims
filed for each period presented, the number of  claims dismissed, settled, or otherwise
resolved for each period, and the average settle ment amount per claim.  Refer to Question 3
of SAB Topic 5:Y.
 Dow Corning Corporation and Subsidiari es Financial Statements, page 117

 Report of Independent Registered Public Accounting Firm, page 119

 5. In future filings, please ensure that you file a signed audit report which indicates the city and
state where the audit report was issued in acco rdance with Rule 2-02(a) of Regulation S-X.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Mr. James B. Flaws Corning Incorporated March 28, 2012 Page 3

  In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Jeffrey Gor don, Staff Accountant, at (202)  551-3866 or, in his absence,
Jeanne Baker, Assistant Chief Accountant, at  (202) 551-3691 if you have questions regarding
these comments.       Sincerely,   /s/ Rufus Decker       Rufus Decker  Accounting Branch Chief