Katherine R. Kelly
	Associate General Counsel & Corporate Secretary
	345 Park Avenue    New York, NY 10154-0037
	Tel 212-546-4852   Fax 212-546-9966
	katherine.kelly@bms.com
	April 20, 2016

VIA EDGAR

Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

Office of Healthcare and Insurance

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, 2015
	Filed February 12, 2016
	File No. 001-01136

Dear Mr. Rosenberg:

 We have received the comment letter (the “Comment Letter”) dated April 19, 2016, 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, 2015.  We are submitting this letter to confirm my conversation with your colleague, Dorman Yale, earlier today regarding the timing of our response to your comments.  As discussed with Ms. Yale, we anticipate providing a complete response by May 17, 2016.

Sincerely,

/s/ Katherine R. Kelly

Katherine R. Kelly

Associate General Counsel &

Corporate Secretary