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                              September 1, 2021

       Roger Byrd
       General Counsel
       EASTMAN KODAK CO
       343 State Street
       Rochester, NY 14650

                                                        Re: EASTMAN KODAK CO
                                                            Form 10-K filed
March 16, 2021
                                                            10-Q filed August
10, 2021
                                                            File No. 001-00087

       Dear Mr. Byrd:

               We have reviewed your filings 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 and any amendment you may file in response
to these comments,
       we may have additional comments.

       Form 10-Q filed August 10, 2021

       Liquidity and Capital Resources, page 42

   1.                                                   The disclosure on page
11 indicates that your $225 million term loan has no financial
                                                        maintenance covenants.
Given the materiality of this item to your liquidity, please
                                                        disclose whether the
loan includes any subjective acceleration clauses or cross-default
                                                        provisions.
       Form 10-K filed March 16, 2021

       Pension and Other Postretirement Benefits, page 31

   2.                                                   You disclose several
material assumptions and state that    significant differences    in actual
                                                        experience would impact
your pension costs and obligations. Given the materiality of your
                                                        pension income, assets
and liabilities to your financial statements, please disclose whether
                                                        these past estimates
and assumptions have materially differed from actual results. See
                                                        Item 303(b)(3) of
Regulation S-K and Section 501.14 of the Financial Reporting
                                                        Codification.
 Roger Byrd
EASTMAN KODAK CO
September 1, 2021
Page 2
3.       The disclosure on page 88 indicates that $3.3 billion of your $3.7
billion in Major U.S.
         Pension Plan Assets are measured at net asset value. Consequently, it
is unclear whether
         these assets have a readily determinable fair value. Please expand
your disclosure to
         enable a better understanding of the nature and risks of these
investments and whether the
         investments, if sold, are probable of being sold at amounts different
from net asset value
         per share. In this regard, certain of the disclosures outlined in ASU
820-10-50-6A would
         appear to be relevant.
4.       Based on the disclosure on page 91, it appears that 33% of your
December 31, 2020 major
         U.S. pension plan investments is comprised of derivative instruments.
Consequently, it is
         not clear whether your loss exposure on these derivatives could
materially exceed the
         carrying value of the investments. Please provide a disclosure that
clarifies this issue and
         identifies all known factors that could precipitate material losses in
your derivatives
         portfolio such as increases in interest rates, decreases in
company-specific or sector-
         specific equity prices, etc. See Section 501.02 of the Financial
Reporting Codification.
        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. You may contact Al Pavot, staff accountant, at (202)
551-3738 or Terence
O'Brien, Branch Chief, at (202) 551-3355 if you have questions regarding our
comments.



FirstName LastNameRoger Byrd                                   Sincerely,
Comapany NameEASTMAN KODAK CO
                                                               Division of
Corporation Finance
September 1, 2021 Page 2                                       Office of Life
Sciences
FirstName LastName