BERKSHIRE HATHAWAY INC.

3555 FARNAM STREET

OMAHA, NEBRASKA 68131

TELEPHONE (402) 346-1400

FAX (402) 346-3375

June 2, 2017

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Washington, D.C. 20549

Re: Berkshire Hathaway Inc.

Form 10-K for the Fiscal Year Ended December 31, 2016

Filed February 27, 2017

File No. 001-14905

Dear Ms. Blume:

The purpose of this letter is to respond to your letter dated May 12, 2017. To assist you in reviewing our response, we preceded our response with a copy (in bold type) of the point as stated in your letter.

Consolidated Balance Sheets, page 64

1. In your response to prior comment 2 you acknowledge that your investments in U.S. Treasury Bills are short-term investments under Rule 7-03(a)1(g) of Regulation S-X. We note that the classification as investments is also consistent with the definition of debt securities in ASC 320-10-20. Under Rules 7-03(a)1 and 7-03(a)2 of Regulation S-X investments are to be presented separately from cash. Please represent to us that in future filings you will present your investments in U.S. Treasury Bills as short-term investments included with your other investments and not with your cash and cash equivalents. In this regard, you are not precluded from highlighting the nature of these short-term investments in a liquidity discussion in Management’s Discussion and Analysis. This comment also applies to the presentation in the Finance and Financial Products section of your balance sheet as Rules 5-02.1 and 5-02.2 of Regulation S-X do not contemplate a subtotal combining marketable securities with cash.

We acknowledge that listing short-term investments under an investment heading in the Consolidated Balance Sheets is a strict application of Regulation S-X Rule 210.7-03(a)1. As stated in our prior response dated April 14, 2017, our consolidated financial statements include significant businesses that fit into Articles 5 and 7 of Regulation S-X. We also note that, as stated at the beginning of Articles 5 and 7 of Regulation S-X, the captions described in the Rules should appear on the face of the statements or notes, except as otherwise permitted by the Commission.

Our U.S. Treasury Bill investments were not included in cash and cash equivalents. We believe that the presentation of U.S. Treasury Bills between cash and cash equivalents and other investments is logical, given their short-durations, and that they are readily convertible to known amounts of cash and possess an insignificant risk of changes in values due to changes in interest rates. We described that position as U.S. Treasury Bills to illustrate the concentration of the asset position.

We believe our presentations were clear, meaningful and relevant given the magnitude of the balances. Nevertheless, in future filings, investments in short-term U.S. Treasury Bills will not be shown under a heading with cash and cash equivalents. To illustrate, our December 31, 2016 and 2015 Consolidated Balance Sheets with the proposed presentations follow.

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 2

BERKSHIRE HATHAWAY INC.

and Subsidiaries

CONSOLIDATED BALANCE SHEETS

(dollars in millions)

	December 31,
	2016		2015
ASSETS
Insurance and Other:
Cash and cash equivalents	$	23,581	$	56,612
Short-term investments in U.S. Treasury Bills		47,338		4,569
Investments in fixed maturity securities		23,432		25,988
Investments in equity securities		120,471		110,527
Other investments		14,364		15,683
Investments in The Kraft Heinz Company (Fair Value: 2016 – $28,418, 2015 – $32,042)		15,345		23,424
Receivables		27,097		23,303
Inventories		15,727		11,916
Property, plant and equipment		19,325		15,540
Goodwill		53,994		37,188
Other intangible assets		33,481		9,148
Deferred charges reinsurance assumed		8,047		7,687
Other		7,126		6,697
		409,328		348,282
Railroad, Utilities and Energy:
Cash and cash equivalents		3,939		3,437
Property, plant and equipment		123,759		120,279
Goodwill		24,111		24,178
Regulatory assets		4,457		4,285
Other		13,550		12,833
		169,816		165,012
Finance and Financial Products:
Cash and cash equivalents		528		7,112
Short-term investments in U.S. Treasury Bills		10,984		—
Investments in equity and fixed maturity securities		408		411
Other investments		2,892		5,719
Loans and finance receivables		13,300		12,772
Property, plant and equipment and assets held for lease		9,689		9,347
Goodwill		1,381		1,342
Other		2,528		2,260
		41,710		38,963
	$	620,854	$	552,257

See accompanying Notes to Consolidated Financial Statements

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 3

Notes to Consolidated Financial Statements

Note 5: Other investments, page 79

2. We acknowledge your response to prior comment 4. Please tell us why your warrants to purchase 700 million shares of Bank of America common stock cannot effectively be net settled and therefore do not qualify for derivative accounting. In this regard, it appears from the warrant agreement included as Annex B to the Securities Purchase Agreement filed as Exhibit 1.1 to Bank of America’s Form 8-K filed on August 25, 2011, that you may exercise the warrant in whole or in part. Since Bank of America common stock is exchange traded and the smallest warrant exercise amount appears to be a single share, it appears that the underlying common stock is readily convertible into cash and that the warrants meet the net settlement criterion as outlined in Case A of Example 7 at ASC 815-10-55-99.

The determination of whether the shares of common stock received upon the exercise of the warrants are readily convertible to cash under ASC 815-10-15-119 requires analysis and judgment. That section provides that if the asset delivered is readily convertible to cash, then it can result in the net settlement criteria being met. ASC 815-10-15-131 also provides that “shares of stock in a publicly traded entity to be received upon the exercise of a stock purchase warrant do not meet the characteristic of being readily convertible to cash if both of the following conditions exist: (a) the stock purchase warrant is issued by an entity only for its own stock (or stock of its consolidated subsidiaries) and (b) the sale or transfer of the issued shares is restricted (other than in connection with being pledged as collateral) for a period of 32 or more days from the date the stock purchase warrant is exercised.” Based on these provisions, the ability to readily convert the instrument to cash can be precluded if there are significant restrictions to the ability to exercise, sell or dispose of the instrument.

While the warrants may be converted in whole or in part, as described in Annex B (Form of Warrant) of the Securities Purchase Agreement, we also considered Article IV of the Securities Purchase Agreement and Annex C (Form of Registration Rights Agreement) to the Securities Purchase Agreement. Article IV provides that the warrants are exercisable only into the stock of the issuer (Bank of America), and the shares received upon exercising the warrants will not be registered under the Securities Act of 1933 (“Act”) when issued, and may not be transferred, except under Rule 144 or under an exemption from registration under the Act. We believe that the sale under Rule 144 or under a registration exemption significantly restricts our ability to readily convert the shares of common stock received upon exercising of the warrants to cash.

Berkshire possesses registration rights pursuant to a Registration Rights Agreement under Annex C to the Securities Purchase Agreement. Those rights allow Berkshire to request that Bank of America register the shares issued upon exercise of the warrants on a best efforts basis. However, that request may only be made after the warrants are exercised and the common shares are issued. Also, while Bank of America is required to use its best efforts to file a registration statement for resale of shares issued upon exercise of the warrants, it has up to 45 days to file a registration statement. In addition, Berkshire is limited to three “demand registration” requests and one “shelf registration” request, which must each occur at least six months apart. The value of common shares to be registered must be in increments of at least $1 billion. Further, the issuer may further delay the registration of the shares under other conditions, as provided in the Registration Rights Agreement.

We believe the restrictions/delays under Article IV and Annex C of the Securities Purchase Agreement significantly impede Berkshire’s ability to readily convert the warrants and the common stock received upon the exercise of the warrants to cash. We, therefore, believe the warrants are not readily convertible to cash based on ASC 815-10-15-119 and that the warrants do not meet the net settlement requirement in paragraph ASC 815-10-15-83 c. Accordingly, we concluded that the warrants did not meet the definition of a derivative.

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 4

Note 14: Unpaid losses and loss adjustment expenses, page 86

3. We acknowledge your response to prior comment 5. Please elaborate on your conclusion for each of your General Re, BHRG and BH Primary claims development tables that you believe that further disaggregation (either by line of business, contract type or claims settlement tail) would not be as meaningful or useful to users of your financial statements as your disclosed aggregate information in understanding potential uncertainty in the timing and amount of cash flows from claims. In your response, specifically address the following:

• Tell us your consideration for including the development of loss reserve estimates in your conclusion, consistent with the basic principle outlined in paragraph BC2 of ASU 2015-09.

• Provide us the information that would be provided in the separate tables by material line of business for each of these segments, if available.

• Provide us the information that would be provided in the separate tables for short-tail business versus long-tail business for your BHRG segment, if available.

• If the information requested in the preceding two bullets is not available, demonstrate to us otherwise that material differing development trends by line of business and/or settlement tail are not obscured by aggregating differing lines of business. In other words, tell us whether material favorable development trends in some lines of business are offset by material unfavorable development trends in other lines of business within your currently presented tables.

In determining the level of detail to include in our Consolidated Financial Statements, we considered the disclosure objectives discussed in BC2 of ASU 2015-09 and ASC 944-40-50-4H. As indicated in BC2, the primary objectives are to increase transparency into the estimation process, improve comparability by requiring consistent disclosure of information, and provide information on the timing, amount and uncertainty of cash flows. As further indicated in BC2, “there is no method to objectively measure the costs to implement the new guidance or the value of improved information in the financial statements.”

We operate a wide variety of property and casualty insurance and reinsurance businesses that offer a wide variety of contracts and coverages. For certain of those businesses, particularly reinsurance, the mix of contracts and coverages can vary widely from year to year and over time based upon changes in prevailing market conditions and underwriting opportunities. As a result, we believe selecting lines of business or contract types that are likely to be significant over time for purposes of these disclosures can be difficult, given the current level of diversification and business levels within General Re, BHRG and BH Primary.

As noted in BC33 of ASU 2015-09, the guidance does not prescribe any specific factor to be used as the basis for disaggregating the disclosures. Rather, it provides flexibility for preparers to consider different approaches. It also provides principal-based guidance and examples concerning approaches to disaggregation. We elected to disaggregate our consolidated loss and loss adjustment expense liabilities based upon our four reportable insurance underwriting segments consistent with one of the examples provided in ASC 944-40-55-9C. As discussed in ASC 944-40-55-9B and as noted in our response dated April 14, 2017, we considered how insurance liabilities for unpaid losses and loss adjustment expenses were presented for other purposes. The level of disaggregation is ultimately a matter of judgment based on the facts and circumstances. We continue to believe that the disaggregated disclosures included in our Consolidated Financial Statements were meaningful and reasonable under the circumstances.

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 5

The following table summarizes our consolidated liability for unpaid losses and loss adjustment expenses as of December 31, 2016. Dollars are in millions.

	December 31, 2016			Percentage of consolidated unpaid losses and loss adjustment expenses
Unpaid losses and ALAE, net of reinsurance recoverable:
GEICO	$	12,981			16.9	%
General Re (18.2% of consolidated liabilities):
Property		1,917			2.5	%
Casualty		12,056			15.7	%
BHRG (13.2% of consolidated liabilities):
Property		4,555			5.9	%
Casualty		5,617			7.3	%
BH Primary (13.2% of consolidated liabilities):
Medical professional liability		3,713			4.8	%
Workers’ compensation		3,357			4.4	%
All other property and casualty lines		3,103			4.0	%
		47,299			61.5	%
Reinsurance recoverable:
GEICO		1,084			1.4	%
General Re		611			0.8	%
BHRG		121			0.2	%
BH Primary		1,099			1.4	%
		2,915			3.8	%
Retroactive reinsurance, unpaid losses and loss adjustment expenses		24,675			32.1	%
Other short-duration insurance, unpaid losses and loss adjustment expenses		1,390			1.8	%
Discount on workers’ compensation reinsurance liabilities		(1,433	)		(1.9	)%
Unpaid unallocated loss adjustment expenses		2,072			2.7	%
		26,704			34.7	%
Unpaid losses and loss adjustment expenses	$	76,918			100.0	%

With respect to the unpaid losses and ALAE of General Re, BHRG and BH Primary, and using 10% of consolidated unpaid losses and loss adjustment expenses as a measure of materiality, only General Re’s casualty liabilities meet that threshold. It should also be noted that while GEICO’s unpaid losses and ALAE represented 16.9% of consolidated unpaid losses and loss adjustment expenses, GEICO’s losses and loss adjustment expenses incurred in 2016, 2015 and 2014 were approximately 68%, 70% and 60%, respectively, of Berkshire’s consolidated losses and loss adjustment expenses incurred in those years. As disclosed in Note 14 to the Consolidated Financial Statements, a substantial portion of GEICO’s claims over the past several accident years were paid within five years of the occurrence.

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 6

In the pages that follow, we are providing further disaggregated net losses and ALAE data for General Re, BHRG and BH Primary in response to the Commission’s request. With respect to General Re and BHRG, the disaggregated data is based on losses that are expected to have short-tails (described as property) and those expected to have long-tails (described as casualty). The processes and methods used by BHRG and General Re in estimating losses are similar. General Re’s net unpaid property losses and ALAE were approximately 2.5% of our consolidated unpaid losses and loss adjustment expenses as of December 31, 2016. Accordingly, such liabilities could be considered immaterial for separate disclosure purposes.

As stated in our prior response dated April 14, 2017, BHRG and General Re reinsure property and casualty risks. Coverages are provided under excess-of-loss and quota-share contracts and the risks assumed can be on a facultative or treaty basis. Under certain contracts, the coverage can apply to multiple lines of business written by the ceding company, whether property, casualty or combined, and the ceding company may not report loss data by line of business consistently, if at all. Further, line of business classifications used in non-U.S. jurisdictions may not be consistent with those in the U.S. In those instances, we allocate losses to coverage based on internal estimates, which may be broadly limited to property or casualty.

With respect to BH Primary, we are providing disaggregated data for medical professional liability and workers’ compensation lines of business. As of December 31, 2016, these were BH Primary’s two largest individual lines of business in terms of unpaid losses and ALAE. The actuarial processes and methods used in estimating medical professional liability and workers’ compensation losses are similar. BH Primary’s “all other” net unpaid losses and ALAE ($3,103 million or 4% of our consolidated unpaid losses and loss adjustment expenses) were attributable to various lines of business, including commercial auto, other liability and various other property and casualty coverages. We believe that such net unpaid losses and ALAE are immaterial for purposes of disaggregated disclosures.

In applying disclosure guidance under ASC 944-40-50, we believe companies are compelled to re-evaluate disaggregated disclosures each year due to changes in facts and circumstances, which may result in changes to the disaggregated components. For instance, significant business acquisitions or reinsurance transactions during the period may result in significant changes in the composition of unpaid losses and loss adjustment expenses, which may result in new or expanded disclosures for categories that become significant or the reduction or elimination of disclosures for categories that are no longer significant. We will re-evaluate our disclosures in 2017 and consider the effects of significant business acquisitions and reinsurance transactions occurring during the year as well as other changes in our businesses and will make appropriate modifications to our disaggregated disclosures.

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 7

General Re – Property

Accident Year	Incurred Losses and ALAE through December 31,																				IBNR and Case Development Liabilities
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007	$	900	$	938	$	900	$	866	$	847	$	836	$	829	$	822	$	819	$	821	$	4
2008				1,032		1,075		1,027		1,007		974		958		942		935		934		7
2009						820		858		803		765		746		740		736		733		8
2010								1,015		1,121		1,065		1,022		974		964		956		21
2011										1,228		1,179		1,070		1,019		977		963		56
2012												917		853		755		718		702		40
2013														1,060		1,078		1,012		967		57
2014																768		767		728		78
2015																		870		875		141
2016																				783		387
						Incurred losses and ALAE													$	8,462
Accident Year	Cumulative Paid Losses and ALAE through December 31,
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007	$	219	$	627	$	729	$	762	$	776	$	783	$	805	$	805	$	807	$	811
2008				277		724		826		876		898		907		909		910		913
2009						213		554		658		695		704		709		712		714
2010								195		589		736		813		860		890		910
2011										248		664		824		856		869		881
2012												143		493		585		595		615
2013														218		635		784		825
2014																116		455		558
2015																		163		495
2016																				120
						Paid losses and ALAE														6,842
						Net unpaid losses and ALAE for 2007—2016 accident years														1,620
						Net unpaid losses and ALAE for accident years before 2007														297
						Net unpaid losses and ALAE													$	1,917

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 8

General Re – Casualty

Accident Year	Incurred Losses and ALAE through December 31,																				IBNR and Case Development Liabilities
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007	$	957	$	977	$	952	$	880	$	826	$	783	$	745	$	737	$	716	$	691	$	69
2008				888		936		876		811		772		755		727		713		701		86
2009						883		932		901		836		777		750		735		698		117
2010								866		934		874		823		783		748		718		135
2011										874		947		827		773		767		706		152
2012												893		997		952		885		833		295
2013														885		1,017		982		887		360
2014																972		1,076		1,066		500
2015																		941		1,124		636
2016																				932		786
						Incurred losses and ALAE													$	8,356
Accident Year	Cumulative Paid Losses and ALAE through December 31,
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007	$	63	$	194	$	291	$	370	$	419	$	455	$	486	$	504	$	515	$	524
2008				53		170		248		311		348		382		406		420		441
2009						51		180		239		299		361		406		433		447
2010								52		193		261		334		383		414		449
2011										54		177		262		334		390		436
2012												56		171		244		321		376
2013														57		194		276		337
2014																55		211		306
2015																		44		198
2016																				51
						Paid losses and ALAE														3,565
						Net unpaid losses and ALAE for 2007—2016 accident years														4,791
						Net unpaid losses and ALAE for accident years before 2007														7,265
						Net unpaid losses and ALAE													$	12,056

Supplemental average historical claims duration information based on General Re’s net losses and ALAE incurred and paid accident year data follows.

	Average Annual Percentage Payout of Incurred Losses by Age, Net of Reinsurance
In Years	1	2	3	4	5	6	7	8	9	10
General Re Combined	14.8%	31.0%	12.2%	6.8%	4.6%	3.2%	2.6%	1.1%	1.2%	0.9%
General Re Property	22.4%	45.1%	14.0%	4.5%	2.4%	1.4%	1.3%	0.1%	0.3%	0.5%
General Re Casualty	6.7%	16.5%	10.3%	9.4%	7.1%	5.5%	4.2%	2.2%	2.3%	1.3%

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 9

BHRG – Property

Accident Year	Incurred Losses and ALAE through December 31,																				IBNR and Case Development Liabilities
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007	$	812	$	748	$	666	$	659	$	627	$	602	$	563	$	555	$	553	$	551	$	2
2008				1,944		1,592		1,696		1,427		1,369		1,429		1,399		1,373		1,367		3
2009						1,520		1,154		1,404		1,365		1,288		1,268		1,231		1,228		1
2010								1,483		1,568		1,502		1,404		1,354		1,328		1,319		40
2011										2,712		2,708		2,544		2,513		2,554		2,537		59
2012												2,190		1,955		1,851		1,649		1,612		93
2013														2,079		1,904		1,629		1,585		239
2014																1,828		1,641		1,570		321
2015																		2,343		2,195		750
2016																				2,444		1,355
						Incurred losses and ALAE													$	16,408
Accident Year	Cumulative Paid Losses and ALAE through December 31,
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007	$	32	$	343	$	467	$	512	$	532	$	537	$	544	$	545	$	548	$	546
2008				182		692		958		1,138		1,219		1,256		1,290		1,344		1,353
2009						183		538		936		1,062		1,120		1,186		1,215		1,223
2010								134		567		870		1,081		1,194		1,219		1,254
2011										320		1,480		1,948		2,184		2,280		2,350
2012												111		713		1,198		1,325		1,393
2013														287		756		1,040		1,193
2014																346		777		999
2015																		401		1,078
2016																				579
						Paid losses and ALAE														11,968
						Net unpaid losses and ALAE for 2007—2016 accident years														4,440
						Net unpaid losses and ALAE for accident years before 2007														115
						Net unpaid losses and ALAE													$	4,555

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 10

BHRG – Casualty

	Incurred Losses and ALAE through December 31,																				IBNR and Case Development Liabilities
Accident Year	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007	$	998	$	1,008	$	993	$	999	$	1,025	$	988	$	1,020	$	1,005	$	947	$	920	$	131
2008				1,444		1,538		1,292		1,476		1,466		1,319		1,284		1,232		1,211		241
2009						1,454		1,704		1,585		1,561		1,559		1,491		1,460		1,440		214
2010								1,393		1,406		1,381		1,367		1,256		1,247		1,232		198
2011										1,706		1,836		1,814		1,927		1,835		1,828		393
2012												1,864		1,923		1,797		1,934		1,919		601
2013														1,247		1,240		1,306		1,247		494
2014																860		944		922		415
2015																		864		875		363
2016																				946		552
						Incurred losses and ALAE													$	12,540
Accident Year	Cumulative Paid Losses and ALAE through December 31,
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007	$	139	$	334	$	424	$	481	$	523	$	583	$	626	$	651	$	663	$	675
2008				182		454		659		698		757		800		841		861		875
2009						189		644		669		875		1,027		1,120		1,121		1,140
2010								59		322		544		655		847		900		923
2011										232		650		924		1,131		1,195		1,250
2012												249		566		882		1,025		1,126
2013														229		314		515		581
2014																91		254		320
2015																		149		276
2016																				199
						Paid losses and ALAE														7,365
						Net unpaid losses and ALAE for 2007—2016 accident years														5,175
						Net unpaid losses and ALAE for accident years before 2007														442
						Net unpaid losses and ALAE													$	5,617

Supplemental average historical claims duration information based on BHRG’s net losses and ALAE incurred and paid accident year data follows.

	Average Annual Percentage Payout of Incurred Losses by Age, Net of Reinsurance
In Years	1	2	3	4	5	6	7	8	9	10
BHRG Combined	14.7%	28.2%	17.2%	9.4%	6.3%	3.9%	2.4%	1.9%	1.0%	0.7%
BHRG Property	14.6%	36.3%	22.2%	10.6%	5.2%	2.7%	2.2%	1.6%	0.6%	(0.4)%
BHRG Casualty	14.0%	19.4%	12.7%	8.1%	7.4%	4.8%	2.5%	1.9%	1.3%	1.3%

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 11

BH Primary – Medical Professional Liability

Accident Year	Incurred Losses and ALAE through December 31,																					IBNR and Case Development Liabilities		Cumulative Number of Reported Claims (in thousands)
	2007		2008		2009			2010		2011		2012		2013		2014		2015		2016
2007	$	653	$	637	$	617		$	583	$	481	$	428	$	394	$	361	$	331	$	315	$	16		15
2008				671		650			620		580		488		438		404		373		350		34		15
2009						694			665		626		608		537		486		437		403		48		16
2010									718		685		663		639		571		505		462		97		17
2011											693		675		647		617		553		538		147		16
2012													692		680		651		627		599		227		18
2013															735		713		694		669		312		18
2014																	793		791		769		481		16
2015																			928		936		698		15
2016																					963		886		11
						Incurred losses and ALAE														$	6,004
Accident Year	Cumulative Paid Losses and ALAE through December 31,
	2007		2008		2009			2010		2011		2012		2013		2014		2015		2016
2007	$	9	$	47	$	95		$	153	$	199	$	237	$	262	$	276	$	289	$	294
2008				10		31			91		148		200		249		279		297		307
2009						(6	)		42		106		178		238		294		322		339
2010									10		61		132		203		263		313		339
2011											10		53		115		190		275		329
2012													11		60		130		211		283
2013															20		75		154		241
2014																	17		83		170
2015																			25		109
2016																					19
				Paid losses and ALAE																	2,430
				Net unpaid losses and ALAE for 2007—2016 accident years																	3,574
				Net unpaid losses and ALAE for accident years before 2007																	139
				Net unpaid losses and ALAE																$	3,713

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 12

BH Primary – Workers’ Compensation

Accident Year	Incurred Losses and ALAE through December 31,																				IBNR and Case Development Liabilities		Cumulative Number of Reported Claims (in thousands)
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007	$	332	$	318	$	314	$	309	$	313	$	292	$	289	$	285	$	287	$	288	$	24		30
2008				365		380		372		370		357		354		347		350		344		36		27
2009						386		359		360		335		334		328		327		328		42		19
2010								372		363		310		309		302		300		298		42		20
2011										459		351		351		345		343		340		68		26
2012												731		729		711		694		675		157		48
2013														845		824		795		766		218		64
2014																1,029		929		884		324		73
2015																		1,153		1,049		510		79
2016																				1,296		895		69
						Incurred losses and ALAE													$	6,268
Accident Year	Cumulative Paid Losses and ALAE through December 31,
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007	$	46	$	129	$	171	$	201	$	220	$	229	$	237	$	242	$	245	$	248
2008				58		142		196		233		251		268		278		285		289
2009						59		137		191		212		235		247		257		265
2010								61		147		174		203		220		232		238
2011										67		115		173		205		229		242
2012												55		219		317		384		423
2013														118		283		394		463
2014																122		299		422
2015																		130		323
2016																				147
				Paid losses and ALAE																3,060
				Net unpaid losses and ALAE for 2007—2016 accident years																3,208
				Net unpaid losses and ALAE for accident years before 2007																149
				Net unpaid losses and ALAE															$	3,357

Supplemental average historical claims duration information based on BH Primary’s net losses and ALAE incurred and paid accident year data follows.

	Average Annual Percentage Payout of Incurred Losses by Age, Net of Reinsurance
In Years	1	2	3	4	5	6	7	8	9	10
BH Primary Combined	15.4%	17.8%	14.5%	11.9%	9.2%	6.8%	4.3%	2.6%	1.9%	1.2%
BH Primary Medical Professional Liability	2.0%	9.2%	13.7%	15.5%	14.2%	12.2%	7.3%	4.6%	3.5%	1.6%
BH Primary Workers’ Compensation	15.2%	22.7%	14.5%	9.4%	6.2%	3.9%	2.7%	2.1%	1.1%	1.0%

Ms. Sharon M. Blume, Accounting Branch Chief

Office of Healthcare and Insurance

United States Securities and Exchange Commission

Page 13

Should you have any questions or further comments, please contact the undersigned at 402-978-5423.

Very truly yours,

BERKSHIRE HATHAWAY INC.

/s/ Marc D. Hamburg

By Marc D. Hamburg

Senior Vice President – Chief Financial Officer

cc: Mark Brunhofer, Senior Staff Accountant

Daniel J. Jaksich, Vice President-Controller