SecProbe.io

June 21 , 2013

Via E -mail
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, 201 2
Filed February 13, 2013
File No. 1 -3247

Dear Mr. Flaws :

We have reviewed your response letter dated May 31, 2013  and have the following
additional comment s. If you disagree, we will consider your explanation as to wh y our comments
are inapplicable.

Please respond to this letter within ten 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 circumstances please tell us why 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, 2012

Corning Incorporated  Consolidated Financial Statements, page 45

Note 20 Reportable Segments, page 83

1. We have read your response to comment 4 from our letter dated May 7, 2013.  You
indicate that your reportable segments are organized according to product categories sold
to external customers  and that e ach of  your reportable segments manufacture and sell
products separate and distinct from other segments .  However, based on your website and
disclosures in your filing we note that your segments contain products that serve dif ferent
markets or have different applications or functions.  For example, your website identifies
products such as ceramic substrates, diesel particulate filters and Corning celcor
substrates for stationary applications within your Environmental Technology  segment
and identifies Corning Gorilla Glass and optical systems and components within your

Mr. Flaws
Corning Incorporated
June 21 , 2013
Page 2

 Specialty Materials segment.  We also note that your Life Sciences segment identifies a
family of brands and products.  Please note this is not meant to be an all -inclusive list of
products identified on your website and in your filing that suggest additional
disaggregated product line information should be presented in accordance with ASC 280 -
10-50-40.   Please advise or revise future filings to  report revenues fro m external
customers for each product and service or each group of similar products.

2. We have read your response to comment 5 from our letter dated May 7, 2013.  You state
that financial information presented to your CODM for your Specialty Materials seg ment
is at the glass substrate level and you do not provide detailed financial informat ion by
business or product line  for allocating resources.  However, in reviewing the Specialty
Materials Q4 2012 Performance Review dated January 22, 2013 , (pages 5, 7, 11 and
elsewhere within the Specialty Materials  report ) we noted various  levels of discrete
financial information such as sales, variable gross margin, fixed costs and gross margin
information that was provided at a level below the Specialty Materials segm ent.  We also
noted discussion of “key takeaways” and fiscal year versus budget information at a level
below the Specialty Materials segment level.  Please identify for us what this discrete
financial information represents.  In doing so, you should addres s the business nature of
this discrete financial information, why it is provided to your CODM and how your
CODM uses this information.   It may also be useful if you clarify what the many
acronyms presented within the Specialty Materials report represent.  Finally, with
reference to ASC 280 -50-1 and in light of this additional discrete financial information,
please reassess whether there are additional operating segments within your Specialty
Materials reportable segment.

Dow Corning Corporation and Subsid iaries Consolidated Financial Statements, page 91

Note 14 Deferred Revenue, page 112

3. We have read your response to comment 6 from our letter dated May 7, 2013 and have
the following comments.

 With regard to the deferred revenues related to average pricing, we note that you
recognized $24.2 million of deferred revenues in 2012.   Please tell us the amount of
deferred revenue recognized in 2012 related to the advanced payments.
 Please clarify whether the volume or timing of such volume changed as a res ult of
amended agreements.   If so, please explain.
 We note that of the $3,572  million  of total deferred revenue  as of December 31, 2012,
$225  million relates  to average pricing and $3,34 7 million relates to advanced
payments received.   Furthermore, a s disclosed in Note 14, as of December 31, 2012,
the current portion of deferred revenue related to advanced payments was determined
based on your estimate of advanced payments to be applied to customer purchases in
the next 12 months. The current  portion as of December 31, 2011 , was determined
based upon application of advanced payments to customer purchases as stipulated by
the underlying agreements. Due to changes in customer agreements resulting from the

Mr. Flaws
Corning Incorporated
June 21 , 2013
Page 3

 uncertainty surrounding the polycrystalli ne silicon market, this  method  was
discontinued.   In light of the fact that Hemlock’s customers are obligated to purchase
minimum quantities of product each year, tell us why there  was a change in the
method  of determining the current portion.
 With reference to the average remaining terms of the sales agreements, please address
the appropriateness of (i) the deferred revenue recognized in 2012 related to both
average pricing and advanced payments and (ii) your determination of the current and
long-term portion of the deferred revenues related to both the average pricing and the
advanced payments received.    Provide a detailed explanation of your method for
amortizing the advance payments, with quantified information as necessary to
illustrate.   Clarify whether the advance payments are being recognized based on
quantities as well as your basis for estimating the total expected quantities to be
delivered under the contracts.
 Please address how your accounting for deferred revenue related to average  pricing
and advanced payments will be impacted if you ultimately ship fewer units than
estimated and/or stipulated in the contracts.
 For each of the periods presented, please tell us whether customers have failed to
order and take delivery of their cont racted volume in a given year and, if so, how the
deferred revenue related to the non -deliveries was accounted for.   If deferred revenue
is not recognized in this scenario, please (i) quantify the amount not recognized in
each period presented, (ii) indica te when such amounts will be recognized; and (iii)
address the appropriateness of this accounting.
 For each period presented as well as the three months ended March 31, 2013  and
2012, please tell us and revise your future filings to disclose the amount of deferred
revenue recognized in income related to average pricing and advanced payments.
 Please also provide a roll -forward  of deferred revenue beginning with January 2010
through the most recent interim period with separate activity for average pricing an d
advanced payments.

 You may contact Tracey McKoy, Staff Accountant, at (202) 551 -3772 or, in her absence,
Jeanne Baker, Assistant Chief Accountant, at (202) 551 -3691  or, the undersigned Accounting
Branch Chief at (202) 551 -3355 , if you have questions r egarding comments on the financial
statements and related matters.

Sincerely,

        /s/ Terence O ’Brien

        Terence O’Brien
        Accounting Branch Chief