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                            November 17, 2023

       Edward Schlesinger
       Chief Financial Officer
       Corning Incorporated
       One Riverfront Plaza
       Corning, NY 14831

                                                        Re: Corning
Incorporated
                                                            Form 10-K for the
Year Ended December 31, 2022
                                                            Form 10-Q for the
Period Ended September 30, 2023
                                                            Form 8-K furnished
October 24, 2023
                                                            File No. 001-03247

       Dear Edward Schlesinger:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment(s).

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-Q for the Period Ended September 30, 2023

       Goodwill, page 27

   1.                                                   We note from your 2022
10-K disclosures that your last quantitative goodwill impairment
                                                        test was performed in
2020 and that the fair value of your reporting units significantly
                                                        exceeded the respective
carrying values. Please tell us how you considered the declines in
                                                        net sales and the
outlook for the remainder of 2023 for certain of your segments as
                                                        discussed on your third
quarter earnings call in determining that an interim impairment
                                                        test was not required
in 2023. Please refer to ASC 350-20-35-3C.
       Form 8-K furnished October 24, 2023

       Exhibit 99, page 1

   2.                                                   The bullet points on
page 1 present core gross margin, core operating margin, and free
                                                        cash flow without the
most directly comparable GAAP measures. Please revise to present
 Edward Schlesinger
Corning Incorporated
November 17, 2023
Page 2
         the most directly comparable measures prior to the non-GAAP measures
in accordance
         with Item 10(e)(1)(i)(A) to prevent undue prominence.
3.       In a related matter, we note that your reconciliation of free cash
flow on page 16 differs
         from the typical calculation of cash flows from operating activities
less capital
         expenditures considering it also adjusts for realized gains on
translated earnings contracts
         and translation losses on cash balances. In order to avoid potential
confusion, please
         revise the title to adjusted free cash flow or a similar description.
Refer to Question
         102.07 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial
         Measures.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       Please contact Heather Clark at 202-551-3624 or Melissa Gilmore at
202-551-3777 with
any questions.



FirstName LastNameEdward Schlesinger                           Sincerely,
Comapany NameCorning Incorporated
                                                               Division of
Corporation Finance
November 17, 2023 Page 2                                       Office of
Manufacturing
FirstName LastName