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    Corning
    Incorporated
    Corning,
    NY 14831
    t
    607-974-9000

    www.corning.com

Confidential treatment requested by Corning Incorporated

GLW-001

[***] - Information omitted and provided under separate cover to the Staff pursuant to Rule 83 (17 C.F.R. §200.83)

September 25, 2025

VIA EDGAR TRANSMISSION

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attention: Melissa Gilmore and Kevin Woody

    Re:
    Corning Incorporated

    Form 10-Q for the Period Ended March 31, 2025

    Filed May 2, 2025

    File No. 001-03247

Dear Ms. Gilmore and Mr. Woody:

We are responding to the comment from the Staff of
the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) in the
letter dated August 27, 2025 to Mr. Edward Schlesinger of Corning Incorporated (the “Company”, “Corning”, “we”
or “our”), relating to the above-referenced filing and the Company’s prior response letters dated (i) June 20, 2025
in response to the Staff’s letter dated June 9, 2025 and (ii) July 14, 2025 in response to the Staff’s letter dated July 1,
2025. The Staff’s comment is set forth below in bold, followed by our related response.

Pursuant to 17 C.F.R. §200.83 (“Rule 83”),
the Company requests confidential treatment for certain portions of this letter that have been redacted from the version filed via the
SEC’s EDGAR system and marked with “[***] - INFORMATION OMITTED AND PROVIDED UNDER SEPARATE COVER TO THE STAFF PURSUANT TO
RULE 83 (17 C.F.R. §200.83),” and that such information be maintained in confidence, not be made part of any public record
and not be disclosed to any person, including in response to any request under the Freedom of Information Act, 5 U.S.C. § 552. An
unredacted version of this letter is being provided to the SEC under a separate cover along with the request for confidential treatment
under Rule 83.

Response Letter dated July 14, 2025

Response to Comment 1

 1. We note your response to our prior comment 1. Please address the following:

 · Specifically describe for us how each specific
constant-currency adjustment is calculated for each of your non-GAAP measures (Core net sales, (loss) income before income taxes, net
(loss) income attributable to Corning Incorporated, etc.). Please provide to us the specific amounts included in the calculations for
the years ended December 31, 2024 and 2023, where these amounts are derived from and whether those amounts can be gleaned from the audited
numbers presented in your audited financial statements. Previously you described for us the exchange rates used and how they are determined
but provided few details of the

    Corning
    Incorporated
    Corning,
    NY 14831
    t
    607-974-9000

    www.corning.com

Confidential treatment requested by Corning Incorporated

GLW-002

[***] - Information omitted and provided under separate cover to the Staff pursuant to Rule 83 (17 C.F.R. §200.83)

remaining component(s) of the computation.
Within your response, please address whether the constant-currency adjustment, translation gain on Japanese yen-denominated debt, net
and translated earnings contract gain, net are interrelated.

 · Within your June 20 response, management
provided a general statement regarding its intent to “reflect the economic impact of our hedging actions and remove the volatility
associated with the currency fluctuations.” Please provide us with more detail regarding management’s intent and how the constant-currency
adjustment achieves that intent. As part of your response, address your disclosure stating that constant-currency rates are applied to
all periods presented and to all foreign exchange exposures during the period, with the exception of the Mexican peso, even though you
may be less than 100% hedged.

 · Lastly, please clarify the calculation
of item (2) translation of Japanese yen- denominated debt, net. For example, describe if the gains or losses are realized and/or unrealized
and if the amounts reflect any adjustments regarding any interest component.

For ease of reference, we have divided our response into sections (a),
(b) and (c) to address each portion of the Staff’s comment. Further, we have elected to address the second portion of the Staff’s
question first in order to provide helpful context for the other two responses.

 (a) Within your June 20 response, management provided a general statement regarding its intent to
“reflect the economic impact of our hedging actions and remove the volatility associated with the currency fluctuations.”
Please provide us with more detail regarding management’s intent and how the constant-currency adjustment achieves that intent.
As part of your response, address your disclosure stating that constant-currency rates are applied to all periods presented and to all
foreign exchange exposures during the period, with the exception of the Mexican peso, even though you may be less than 100% hedged.

As noted in our prior response letters, Corning operates globally
and is exposed to significant foreign currency risk due to the imbalance between the currencies in which we sell products and those in
which we incur expenses. This imbalance creates inherent exposure to exchange rate fluctuations that can significantly impact our reported
financial results.

To mitigate this risk, Corning maintains a hedging program that includes
foreign exchange forwards, option contracts, and foreign-denominated debt. We use these instruments to hedge our currency exposures for
multiple years at consistent exchange rates to establish greater stability in our U.S. dollar revenues, expenses and cash flows over multi-year
periods. The resulting stable currency environment supports long-term operational decision-making, allocation of capital and other resources,
and allows performance to be assessed on operational factors without the effects of short-term currency volatility.

Our constant-currency reporting is intended to report core performance
measures that are aligned with the stable currency environment provided by our hedging program. Specifically, we retranslate revenues
and expenses using our core rates, which are derived from the weighted average of hedge rates in place, rather than spot rates. Given
our hedge rates are intentionally kept consistent for extended periods to provide our operations with a stable currency environment for
as long as is practicable, our core rates likewise remain consistent for extended periods. The constant-currency adjusted measures included
in our public disclosures are the same core performance measures used internally by management for evaluating segment performance, allocating
resources, and determining incentive compensation. Presenting these measures to our investors, as a supplement to our GAAP results, provides
investors with the same views

    Corning
    Incorporated
    Corning,
    NY 14831
    t
    607-974-9000

    www.corning.com

Confidential treatment requested by Corning Incorporated

GLW-003

[***] - Information omitted and provided under separate cover to the Staff pursuant to Rule 83 (17 C.F.R. §200.83)

of operational results that management relies on internally and offers
an understanding of performance within the stable currency environment created by our hedging program.

We recognize that many companies present constant-currency information
by retranslating prior-period results using the current-period average exchange rates. Our methodology differs in that we apply hedge-derived
core rates that remain consistent across reporting periods, unless they no longer align with our hedge portfolio. We believe this approach
provides a meaningful view of our performance because it better reflects the stable currency environment created by our hedging program
in which our businesses are managed while allowing for a comparison of that performance over multi-year periods. This is especially important
given our significant and long-dated exposures to foreign currency risk, particularly to the Japanese yen in our Display segment.

We recognize that it is not practicable to hedge 100% of our foreign
currency exposures, given the dynamic nature of our operations. At the same time, Corning does not engage in speculative hedging and maintains
controls to avoid being over-hedged. We apply our constant-currency rates consistently across materially significant exposures, but do
not intend to suggest they reflect 100% hedge coverage at any point in time. Rather, our methodology uses hedge-derived rates as a proxy
for our stable currency environment, while maintaining the ability to compare our core results over an extended period. This allows management
to simultaneously review operational trends, evaluate the effectiveness of Corning’s hedging program in alignment with its risk
mitigation policies, and identify key growth drivers, while providing valuable insights regarding the performance of our businesses in
the face of the long-term development and investment cycles inherent in our businesses.

While we believe our current disclosures provide appropriate
context, we intend to enhance our future non-GAAP disclosures to further clarify that constant-currency rates are derived from our hedge
portfolio and applied consistently across significant exposures, but do not imply 100% hedge coverage of all exposures.

 (b) Specifically describe for us how each specific constant-currency adjustment is calculated for
each of your non-GAAP measures (Core net sales, (loss) income before income taxes, net (loss) income attributable to Corning Incorporated,
etc.). Please provide to us the specific amounts included in the calculations for the years ended December 31, 2024 and 2023, where these
amounts are derived from and whether those amounts can be gleaned from the audited numbers presented in your audited financial statements.
Previously you described for us the exchange rates used and how they are determined but provided few details of the remaining component(s)
of the computation. Within your response, please address whether the constant-currency adjustment, translation gain on Japanese yen-denominated
debt, net and translated earnings contract gain, net are interrelated.

Constant-Currency Adjustment Calculation

Subsections I through IV below provide a detailed description
of our constant-currency adjustment calculations with respect to Japanese yen, Korean won, Chinese yuan, New Taiwan dollar, euro, and
Mexican peso (our “core currencies”) for the years ended December 31, 2024 and 2023 for each of the core performance measures
included in our Annual Report on Form 10-K. Please note that constant-currency adjustments for the Mexican peso did not begin until January
1, 2024.

    Corning
    Incorporated
    Corning,
    NY 14831
    t
    607-974-9000

    www.corning.com

Confidential treatment requested by Corning Incorporated

GLW-004

[***] - Information omitted and provided under separate cover to the Staff pursuant to Rule 83 (17 C.F.R. §200.83)

 I. Core Net Sales

Calculation:

The constant-currency adjustment used in the calculation
of core net sales is calculated by dividing the net sales currency exposure amounts for each core currency by the applicable average spot
rates for each month in the period, then subtracting this value from the quotient of the net sales currency exposure amount divided by
the applicable core rate. This calculation is performed monthly for each of our core currencies.

2024 and 2023 Amounts:

For the years ended December 31, 2024 and 2023, the constant-currency
adjustment used in determining core net sales was $1,309 and $992 million, respectively.

The tables below disaggregate the total constant-currency
adjustments by currency and reflect the inputs to the calculation:

    A
    B
    C
    (A/C)-(A/B)

    Full-Year 2024: Net Sales
    Net Sales

Currency

Exposures

(millions)

    Spot

    Rate

    Core

    Rate

    Constant

    Currency Adj

    (millions)

    JPY
    ¥
    [***]
    ¥
    [***]
    ¥
    107
    $
    [***]

    KRW
    ₩
    [***]
    ₩
    [***]
    ₩
    1,175
    $
    [***]

    TWD
    NT$
    [***]
    NT$
    [***]
    NT$
    N/A
    $
    [***]

    CNY
    ¥
    [***]
    ¥
    [***]
    ¥
    6.7
    $
    [***]

    EUR
    €
    [***]
    €
    [***]
    €
    0.81
    $
    [***]

    MXN
    MX$
    [***]
    MX$
    [***]
    MX$
    20
    $
    [***]

    Total

    $
    1,309

    A
    B
    C
    (A/C)-(A/B)

    Full-Year 2023: Net Sales
    Net Sales

 Currency

 Exposures

 (millions)

    Spot

    Rate

    Core

    Rate

    Constant

 Currency Adj

    (millions)

    JPY
    ¥
    [***]
    ¥
    [***]
    ¥
    107
    $
    [***]

    KRW
    ₩
    [***]
    ₩
    [***]
    ₩
    1,175
    $
    [***]

    TWD
    NT$
    [***]
    NT$
    [***]
    NT$
    N/A
    $
    [***]

    CNY
    ¥
    [***]
    ¥
    [***]
    ¥
    6.7
    $
    [***]

    EUR
    €
    [***]
    €
    [***]
    €
    0.81
    $
    [***]

    Total

    $
    992

 A. The net sales currency exposure amounts included in the tables above are the total value of the underlying sales transaction exposures
for our foreign businesses transacting in each such core currency. These amounts form part of the consolidated net sales reported in our
audited financial statements. While these amounts are not separately disclosed in our public filings, they are derived directly from the
same general ledger and underlying transaction-level records that support our audited consolidated results and are subject to the same
internal controls.

    Corning
    Incorporated
    Corning,
    NY 14831
    t
    607-974-9000

    www.corning.com

Confidential treatment requested by Corning Incorporated

GLW-005

[***] - Information omitted and provided under separate cover to the Staff pursuant to Rule 83 (17 C.F.R. §200.83)

 B. The spot rates included in the tables above reflect the weighted average of the monthly average spot rates for each currency, weighted
by the monthly net sales base amounts. The daily spot rates used in this process are obtained from an independent third-party source,
and while not separately disclosed in our public filings, they are the same spot rates used in translating foreign currency sales within
our audited financial statements.

 C. In addition to monthly USD translations at spot rates, for each of our core currencies we also retranslate sales at the applicable
core rate. The core rates included in the tables above reflect the applicable core rate for the periods presented. Our core rates are
determined by management through a well-established and controlled process further described in our prior correspondence, and are set
forth in the footnotes to our GAAP to core reconciliation included in our Annual Report on Form 10-K and Quarterly Reports on Form 10-Q.

 II. Core Income before Income Taxes

Calculation:

The constant-currency adjustments used in the calculation of core income
before income taxes are performed at each income statement line underlying income before income taxes. Specifically, the foreign-denominated
amount of each such line is divided by the applicable average spot rate for each month in the applicable period, then this value is subtracted
from the quotient of the amount of such income statement line divided by the applicable core rate. For example, for Japanese yen, sales
denominated in yen as well as cost of goods sold and operating expenses denominated in yen are calculated at both spot and core rates,
and the difference flows through to the constant-currency adjustment at the income before taxes level. This calculation is performed monthly
for each of our core currencies.

2024 and 2023 Amounts:

For the years ended December 31, 2024 and 2023, the constant-currency adjustment
used in d