SecProbe.io

November 2, 2010
  David J. Anderson Chief Financial Officer Honeywell International Inc. 101 Columbia Road Morris Township, New Jersey 07962

Re: Honeywell International Inc.
 Form 10-K for Fiscal Year Ended December 31, 2009  Filed February 12, 2010  Form 10-Q for Quarterly Period Ended June 30, 2010  Filed July 23, 2010  File No. 001-08974

Dear Mr. Anderson:

We have reviewed your response letter da ted September 23, 2010 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 10 business days by confirming that you will revise
your document in future filings and providing an y requested information.  If you do not believe
our comments apply to your facts and circumst ances, 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 Fiscal Year Ended December 31, 2009

 Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Consolidated Results of Operations, page 22

1. Refer to your response to our prior comment one .  Please disclose the basis for estimated
amounts provided in your disclosure (that is, the reason for estimates and how estimated
amounts were derived) so that  investors may have a full qualitative understanding of your
results.

David J. Anderson Honeywell International Inc.
November 2, 2010 Page 2

Review of Business Segments, page 26

2. We have reviewed your response to our pr ior comment five, and we acknowledge that
you plan to disclose total “COGS” for each segm ent.  However, it appears that you plan
to continue to discuss segment operating resu lts primarily in terms of segment revenue
and segment profit, without providing a direct discussion and analysis of segment costs.
In this regard, we note that segment profit is a net amount.  As such, we believe that
segment profit, as well as any changes theret o, would be more thoroughly and effectively
explained if your disclosure also presented, an alyzed, and discussed the associated costs.
In this regard, we believe that, at a minimu m, you should present in tabular fashion the
major cost categories (i.e., cost of goods sold, SG&A, and other material items (e.g.,
pension expense, repositioning and other charges)) for each segment, accompanied by an appropriate level of analysis and, as indicated in your respon se to our prior comment one,
quantification.  Additionally, to the extent material, your tabular presentation should present other items attributed to your segmen ts in arriving at the profit for each segment
(e.g., equity income/loss of affilia tes, as indicated in note “a” to the table on page 35 of
your Form 10-Q for quarterly period ended J une 30, 2010), so that investors may have a
clear understanding of how you arrive at the profit for each segment.  Please revise your disclosure accordingly, and provide us with  a copy of your intended revised disclosure.
 Liquidity and Capital Resources

 Cash Flow Summary, page 37

3. Please refer to your response to our prior comment seven.  We note that your proposed disclosure regarding “cash provided by ope rations” continues to reference, quantify,
and/or explain items such as changes in working capital, change s in net income, and
reconciling items included on the face of your st atements of cash flows.  In this regard,
we continue to believe that it would be more meaningful to discuss certain of these items in terms of the underlying cash receipts and cas h disbursements, or changes thereto.  For
example, we believe that you should quantif y the actual change in cash disbursements
related to inventory, instead of citing the related reconciling item presented in your
statement of cash flows prepared using the indi rect method.  In this regard, it is not clear
to us how the $479 million reconciling item from  your statement of cash flows cited in
the proposed disclosure is repr esentative of the decline in cash disbursements related to
inventory.  Similarly, we beli eve it would be more approp riate for you to quantify and
discuss other changes in terms of cash, such as cash receipts from customers and cash
payments for accounts payable and accrued expenses, rather than citing the change in your reported net income.  Furthermore, it is  not clear how refere nce to a noncash item
like deferred income taxes has an impact in terms of cash.  Please advise in this regard
and revise your analysis accordingly to address the preceding items.  Provide your
proposed revised disclosure addressing the indi cated items as part of your response.

David J. Anderson Honeywell International Inc. November 2, 2010 Page 3

You may contact Jeffrey S ears at 202-551-3302 or Doug Jones at 202-551-3309 if you
have questions regarding comments on the financial statements and related matters.  Please contact me at 202-551-3380 w ith any other questions.

Sincerely,
      Lyn Shenk
Branch Chief