PAGE <1>



December 15, 2006


Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549


Attention:  Angela Crane, Branch Chief


Regarding:  Eastman Kodak Company
            Form 10-K for the fiscal year ended December 31, 2005
            File No. 001-00087



Please find below the Company's response to the Staff's letter
to me dated December 5, 2006.  If you have any questions,
please call Diane Wilfong (Kodak) at (585) 781-5650, Laurence
Hickey (Kodak) at (585) 724-3378 or Brian Lane (Gibson, Dunn &
Crutcher) at (202) 887-3646.

Please address all future correspondence regarding this matter
to myself, as I have succeeded Robert Brust as the Company's
Chief Financial Officer.





                              Sincerely,

                              /s/ Frank S. Sklarsky

                              Frank S. Sklarsky



cc: Brian Lane, Esq.


PAGE <2>


Form 10-K for the fiscal year ended December 31, 2005

General

1.   We note the representation in your November 21, 2006,
     response, that, to the best of your knowledge, understanding
     and belief, none of the products technology or services that
     your foreign subsidiaries provide into Iran, Syria or Sudan
     were designed or intended for military applications.  Please
     clarify for us whether, to the best of your knowledge,
     understanding and belief, any of the products, technology or
     services provided into those countries by your foreign
     subsidiaries have military application(s).  Please describe
     possible military uses of which you are aware; advise us
     whether, to the best of your knowledge, understanding or
     belief, the referenced products, technology or services have
     been put to military use by any of the referenced countries;
     and discuss any specific military use by any of the
     referenced countries of which you are aware.

Kodak interprets the term "military application" as used above to
mean goods, services or technology that were designed,
manufactured or intended for use by a military organization to
advance its warfare capabilities.  Accordingly, none of the
products, technologies or services Kodak foreign subsidiaries are
selling or have sold into Iran, Sudan or Syria has a military
application.

Kodak interprets the term "military use" as used above to mean
goods, services or technology that were designed, manufactured or
intended for use by a military organization to advance its
warfare capabilities or that have a "dual use" as defined by the
U.S. Bureau of Industry and Security (BIS).  Under this
definition, only one of the product lines Kodak has sold into the
referenced countries has a military use.  Our line of non-
destructive testing films and developing chemicals has the
potential to be designated as "dual use" by the BIS.  These
products are designed to assist in the identification of cracks
and other flaws in oil and gas pipelines and in commercial
aircraft.  Kodak non-destructive testing films and developing
chemicals are not marketed for military use.

Further, to the best of our knowledge, understanding and belief,
no Kodak products, technologies or services are being or have
been put to military use in Iran, Sudan or Syria.  Finally, to
the best of our knowledge, information and belief, no Kodak
products, technologies or services have been sold to military
organizations in the referenced countries.