Mail Stop 7010

      November 17, 2005



Mr. James B. Flaws
Vice Chairman and Chief Financial Officer
Corning, Incorporated
One Riverfront Plaza
Corning, New York 14831

	RE: 	Form 10-K for the Fiscal Year ended December 31, 2004
Forms 10-Q for the Fiscal Quarters ended March 31, 2005, June 30,
2005 and September 30, 2005
                    	File No. 1-3247


Dear Mr. Flaws:

		We have reviewed your response letter dated November 4,
2005 and have the following additional comments.  If you disagree
with a comment, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary.  Please be
as
detailed as necessary in your explanation.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.







Form 10-K for the year ended December 31, 2004

General
1. Where a comment below requests additional disclosures or other
revisions to be made, please show us in your response what the
revisions will look like.  These revisions should be included in
your
future filings, including your interim filings where applicable.

Financial Statements

Note 1 - Summary of Significant Accounting Policies

Basis of Presentation and Principles of Consolidation
2. We have reviewed your response to prior comment 4.  You
disclose
that the sole purpose of all three variable interest entities is
to
lease transportation equipment to you and that you are the primary
beneficiary for only one of these three entities.  Please also
disclose how you determined you were not the primary beneficiary
for
the two entities that are not consolidated.

Foreign Currency Translation and Transactions
3. We have reviewed your response to prior comment 5.  It is not
clear what significant changes in economic facts and circumstances
led you to determine it was appropriate to change the functional
currency of your Taiwanese subsidiary from the New Taiwan Dollar
to
the Japanese Yen.  Given that it appears your primary basis for
the
change in functional currency is due to the currency in which
capital
expenditures are denominated and product sales are priced and
transacted, please tell us the currency in which capital
expenditures
were denominated and sales of products were priced and transacted
during the nine months ended September 30, 2005 and each of the
two
years ended December 31, 2004.  If capital expenditures and sales
transactions were denominated in multiple currencies, please tell
us
the estimated dollar amount and percentage for each of these
currencies.  Please also provide us with a detailed explanation as
to
why you believe it is appropriate to use the Japanese Yen as the
functional currency with reference to Appendix A of SFAS 52.   If
multiple currencies are used for any of the indicators provided in
Appendix A, please tell us the estimated dollar amount and
percentage
for each of these currencies.





Form 10-Q for the quarter ended September 30, 2005

General
4. Please address the comments above in your interim filings as
well.

Item 4 - Controls and Procedures
5. You disclosed an incomplete definition of disclosure controls
and
procedures per Rules 13a-15(e) and 15d-15(e) of the Exchange Act.
Please clarify, if true, that your disclosure controls and
procedures
were effective to ensure that information required to be disclosed
by
you in the reports that you file or submit under the Exchange Act
is
accumulated and communicated to your management, including your
principal executive and principal financial officers, or persons
performing similar functions, as appropriate to allow timely
decisions regarding required disclosure.



*    *    *    *



      		Please respond to these comments within 10 business
days, or tell us when you will provide us with a response.  Please
provide us with a response letter that keys your responses to our
comments and provides any requested information.  Detailed letters
greatly facilitate our review.  Please file your response on EDGAR
as
a correspondence file.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

       	If you have any questions regarding these comments,
please
direct them to Gus Rodriguez, Staff Accountant, at (202) 551-3752
or,
in his absence, Nudrat Salik, Staff Accountant, at (202) 551-3692.



          						Sincerely,



								Rufus Decker
								Branch Chief
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James B. Flaws
Corning Incorporated
November 17, 2005
Page 1 of 3



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE