Katherine R. Kelly | ||||
Vice President & Assistant General Counsel | ||||
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345 Park Avenue | New York, NY 10154-0037 | |||
Tel 212-546-4852 | Fax 212-605-9475 | |||
katherine.kelly@bms.com | ||||
November 29, 2010 |
VIA EDGAR
Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: | Bristol-Myers Squibb Company |
Form 10-K for the Year Ended December 31, 2009
Filed February 19, 2010
File No. 1-1136
Dear Mr. Rosenberg:
This letter is submitted based on our discussion with the staff (the Staff) of the Securities and Exchange Commission (the Commission) during the teleconference on November 23, 2010 with respect to the comment letter (the Comment Letter) dated November 16, 2010 regarding the comment of the Staff with respect to the above referenced Annual Report on Form 10-K for the year ended December 31, 2009 (2009 Form 10-K) of Bristol-Myers Squibb Company (the Company or BMS).
As discussed during the teleconference, the Company acknowledges that, if, in connection with the preparation of future periodic filings, it believes that the amount of expected future research and development expenses will likely be significantly different from historical levels, the Company will disclose this expected change, consistent with the disclosures about known trends or uncertainties reasonably expected to have a material impact on results, cash flows or liquidity that are required as part of Managements Discussion and Analysis of Financial Condition and Results of Operations.
In connection with this response, BMS acknowledges that (i) BMS is responsible for the adequacy and accuracy of the disclosure in the filing; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and (iii) BMS may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under federal securities laws of the United States.
If you have any questions with respect to this letter, please contact the undersigned at (212) 546-4852.
Sincerely, |
/s/ Katherine R. Kelly |
Katherine R. Kelly |
Vice President & Assistant General Counsel |
cc: | Charles Bancroft, Bristol-Myers Squibb Company |
Sandra Leung, Bristol-Myers Squibb Company
Linda Griggs, Morgan, Lewis & Bockius LLP