SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4628

       DIVISION OF
CORPORATION FINANCE

   July 22, 2011
Via Facsimile

Kathleen A. Winters Vice President and Controller Honeywell International Inc. 101 Columbia Road
Morris Township, NJ 07962

 Re: Honeywell International Inc.
  Form 10-K for the Fiscal Year Ended December 31, 2010   Filed February 11, 2011   File No. 001-8974   Response Letter Filed July 8, 2011
Dear Ms. Winters:
 We have reviewed your response letter  and have the following comments.

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 circumstan ces, please tell us why in
your response.
After reviewing the information you provide  in response to these comments, we
may have additional comments.

 General

1. We note from your response to our co mment letter dated June 9, 2011, that
you have committed to accept no new busin ess in Iran; that you have ceased
doing business in Sudan; and that you had some revenues from Iran in 2011.
Please tell us whether you have ongoing le gacy or other business in Iran or
Sudan, or otherwise have remaining cont ractual obligations with respect to
business in those countries.  Tell us whether any such remaining business
involves products or services for refine ry and petrochemical applications.
2. Please tell us whether the products and se rvices that you sell or have sold in
Iran, Syria or Sudan, other than thos e licensed by the Commerce Department

Kathleen A. Winters
Honeywell International Inc. July 22, 2011 Page 2
 for use in connection with the overhaul of a Syrian airline, are on the
Commerce Control List.

 Please contact Jennifer Hardy, Special C ounsel, at (202) 551- 3767 or me at (202)
551-3470 if you have any questions about  the comments or our review.

        S i n c e r e l y ,

        /s/ Cecilia Blye          C e c i l i a  B l y e ,  C h i e f          Office of Global Security Risk   cc:  Max Webb   Assistant Director  Division of Cor poration Finance