October 31, 2018

Ron Edmonds
Co-Controller
DowDuPont Inc.
c/o The Dow Chemical Company
2211 H.H. Dow Way
Midland, MI 48674

Jeanmarie Desmond
Co-Controller
DowDuPont Inc.
c/o E.I. du Pont de Nemours and Company
974 Centre Road
Wilmington, DE 19805

       Re: DowDuPont Inc.
           Form 10-K for the Year Ended December 31, 2017
           Filed February 15, 2018
           Definitive Proxy Statement on Schedule 14A
           Filed March 16, 2018
           Form 8-K filed October 18, 2018
           File No. 001-38196

Dear Mr. Edmonds:

       We have reviewed your October 9, 2018 response to our comment letter and
have the
following comments. In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

      After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
September 26, 2018 letter.
 Ron Edmonds
FirstName LastNameRon Edmonds
DowDuPont Inc.
Comapany NameDowDuPont Inc.
October 31, 2018
October 31, 2018 Page 2
Page 2
FirstName LastName
Definitive Proxy Statement on Schedule 14A

Compensation Discussion and Analysis, page 30

1.       We note your response to comment 6 of our letter dated September 26,
2018. On page ix,
         you state each component of target pay benchmarked to median of either
the peer group or
         the general market.Please note that the term benchmarking includes
using compensation
         data about other companies as a reference point on which, either
wholly or in part, to base,
         justify or provide a framework for a compensation decision. Please see
Question 118.05
         of Compliance and Disclosure Interpretations for Regulation S-K. To
the extent you
         engaged in benchmarking, for each applicable component of your
compensation program,
         please identify the benchmark and disclose where actual compensation
fell within the
         targeted parameters. To the extent actual compensation was outside the
targeted range,
         please explain why. Please see Item 402(b)(1)(v) and (b)(2)(xiv) of
Regulation S-K.



Form 8-K filed on October 18, 2018

Item 8.01 - Other Events, page 1

2.       We note your disclosure that on October 18, 2018, DuPont, a subsidiary
of DowDuPont,
         announced that it would recognize non-cash impairment charges
associated with DuPont's
         agriculture reporting unit in the quarter ended September 30, 2018, of
$4.5 billion for
         goodwill and $0.1 billion for other assets. We also note your
disclosure
         that DowDuPont's results of operations and financial statements for
the quarter ended
         September 30, 2018, will not be impacted by DuPont's expected $4.5
billion goodwill
         impairment charge, as the fair value of DowDuPont's agriculture
reporting unit continues
         to exceed its carrying value at September 30, 2018. Please address the
following:
           Tell us the significant assumptions DuPont used to determine the
estimated fair value
             of its agriculture reporting unit during the quarter ended
September 30, 2018 and more
             fully explain the facts and circumstances that resulted in these
impairments being
             recorded during the current interim period;
           Tell us the significant assumptions DowDuPont used to determine the
estimated fair
             value of its agriculture reporting unit during the quarter ended
September 30, 2018 and
             more fully explain the differences between the agriculture
reporting units of
             DowDuPont and DuPont;
           Tell us the amount or percent by which the estimated fair value of
DowDuPont's
             agriculture reporting unit exceeded its carrying value at
September 30, 2018; and
           Explain if and how the impairments recorded by DuPont will be
reflected in
             DowDuPont's financial statements either before or after the
intended spin-off of the
             Agriculture Division.
 Ron Edmonds
DowDuPont Inc.
October 31, 2018
Page 3

       You may contact Dale Welcome at 202-551-3865 or Anne McConnell at
202-551-3709 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Sergio Chinos at 202-551-7844 or Jay Ingram at 202-551-3397 with any
other questions.



                                                         Sincerely,
FirstName LastNameRon Edmonds
                                                         Division of
Corporation Finance
Comapany NameDowDuPont Inc.
                                                         Office of
Manufacturing and
October 31, 2018 Page 3                                  Construction
FirstName LastName