Katherine R. Kelly Vice President & Assistant General Counsel
	345 Park Avenue    New York, NY 10154-0037 Tel 212-546-4852   Fax 212-546-9966 katherine.kelly@bms.com
	August 13, 2013

VIA EDGAR

Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Re: Bristol-Myers Squibb Company

Form 10-K for the Fiscal Year Ended December 31, 2012

Filed February 15, 2013

File No. 001-01136

Dear Mr. Rosenberg:

We have received the comment letter (the “Comment Letter”) dated August 9, 2013 regarding the comments of the staff of the Securities and Exchange Commission (the “Commission”) with respect to the above-referenced Form 10-K for the fiscal year ended December 31, 2012. We are submitting this letter to confirm our conversation with your colleague, Mr. James Peklenk, on August 12, 2013 regarding the timing of our response to your comments. We anticipate providing a complete response by September 9, 2013.

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