SecProbe.io

May 17, 201 2

 Via E -mail
 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 Fiscal Y ear Ended December  31, 2011
Filed February  17, 201 2
File No. 001-08974

Dear Ms. Winters :

We have reviewed your filing an d have the following comment s.  Our comment s ask you
to provide us with information so we may better understand your disclosure s.

Please respond to this letter within ten business days by confirming that you will revise
your document in future filings and providing the requested information.   If you do  not believe
our comment s applies to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comment s, we may
have  additional comments.

Cybersecurity incidents cou ld disrupt business operations, page 12

1. We note that you rely on information technology and systems for many of your business
operations.   We also note that you disclose that you employ comprehensive measures to
prevent, detect, address and mitigate thre ats to your technology and systems.   Please describe
to us the types of cybersecurity threats and attacks that you have experienced recently and the
related consequences.   In addition, tell us what consideration you gave to tailoring your risk
factor discl osure to more clearly state that you have been subject to attacks in the past and to
highlight the potential consequences of the types of attacks that are most concerning to you.
Please refer to the Division of Corporation Finance’s Disclosure Guidance Top ic No 2 at
http://www.sec.gov/divisions/corpfin/guidance/cfguidance -topic2.htm  for additional
information.

Kathleen A. Winters
Honeywell International Inc.
May 17, 2012
Page 2

 Management’s Discussion and Analysis, page 23

Critical Accou nting Policies, page 47

Sales Recognition on Long -Term Contracts, page 52

2. We note your disclosure that you recognized approximately 16 percent of your total net sales
using the percentage -of-completion method for long -term contracts in your Automation and
Control Solutions, Aerospace and Performance Materials and Technologies segm ents and
revenue and cost estimates are regularly monitored and revised based on changes in
circumstances.  Please tell us the aggregate gross amounts of favorable and unfavorable
changes in estimates recognized in 2011, 2010 and 2009.

We urge all per sons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its mana gement are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 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.

You may contact Patrick Kuhn at (202) 551 -3308 or me at (202) 551 -3380 with any
questions  regarding comments on the financial statements and related matte rs.  Please contact
Nolan McWilliams at (202) 551 -3217 or Lauren Nguyen at (202) 551 -3642  with any other
questions.

Sincerely,

 /s/ Lyn Shenk

Lyn Shenk
Branch Chief