SecProbe.io

Mail Stop 3561
 June 4, 2009
 David J. Anderson
Chief Financial Officer
Honeywell International Inc.
101 Columbia Road Morris Township, New Jersey 07962

Re: Honeywell International Inc.
File No. 001-08974
Form 10-K: For the Fiscal Year Ended December 31, 2008

Dear Mr. Anderson:

       We have reviewed the above referenced filing and have the following comment. Unless
otherwise indicated, we believe you should revise future filings in response to this comment. If you
disagree, we will consider your explanation as to why a revision is unnecessary. Please be as detailed
as necessary in your explanation.

The purpose of our review process is to assist you in your compliance with the applicable
disclosure requirements and to enhance the overall disclosure in your filings. We look forward to
working with you in these respects and welcome any questions. Feel free to call us at the telephone numbers listed at the end of this letter.

Please file your response to our comment via EDGAR, under the label “corresp,” within ten
business days from the date of this letter.

Form 10-K: For the fiscal year ended December 31, 2008

Item 7. Managements Discussion and Analysis page 22

Consolidated Results of Operations page 22

In future filings please quantify, discuss and anal yze changes in costs of products and services
sold both in the aggregate and fo r each segment on a stand-alone ba sis in addition to your current
disclosure which is made in the cont ext of gross margin and segment profit.

********

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in
your filings to be certain that the filings include all information required under the Securities

Honeywell International Inc.
June 4, 2009 Page 2 of 2
2 Exchange Act of 1934 and that they have provided all information investors require for an informed
investment decision. Since the company and its management are in possession of all facts relating to
a company’s disclosure, they are responsible for th e accuracy and adequacy of the disclosures they
have made.
In connection with responding to our comment, please provide, in writing, a statement from
the company acknowledging that:

• the company is responsible for the adequacy and accuracy of the disclosure in its filings;

• 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 federal securities laws of the United States.

In addition, please be advised that the Divisi on of Enforcement has access to all information
you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
You may contact Aamira Chaudhry at 202-551-3389  with any questions. You may also call
me at 202-551-3380.

                             Sincerely,

Lyn Shenk
    Branch Chief