-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, UmFd0Ktbw5N+agK9mDy6j5vniuUI5f/5W8H9hPXdzd80hIsqI7xbB7CzSepOrWYp 273WYWRq9XWvLuo7ioIvnw== 0000031235-07-000030.txt : 20070323 0000031235-07-000030.hdr.sgml : 20070323 20070130143348 ACCESSION NUMBER: 0000031235-07-000030 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20070130 FILER: COMPANY DATA: COMPANY CONFORMED NAME: EASTMAN KODAK CO CENTRAL INDEX KEY: 0000031235 STANDARD INDUSTRIAL CLASSIFICATION: PHOTOGRAPHIC EQUIPMENT & SUPPLIES [3861] IRS NUMBER: 160417150 STATE OF INCORPORATION: NJ FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 343 STATE ST CITY: ROCHESTER STATE: NY ZIP: 14650 BUSINESS PHONE: 7167244000 MAIL ADDRESS: STREET 1: 343 STATE STREET CITY: ROCHESTER STATE: NY ZIP: 14650 CORRESP 1 filename1.txt 1 January 30, 2007 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 Dear Ms. Crane: Please find attached the Company's response to the Staff's letter to me dated January 8, 2007. 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. Sincerely, /s/ Frank S. Sklarsky Frank S. Sklarsky Chief Financial Officer and Executive Vice President Attachment cc: Brian Lane, Esq. 2 Form 10-K for the fiscal year ended December 31, 2005 General 1. We refer you to the representation in your response letter dated December 15, 2006, that your line of non-destructive testing films and developing chemicals has the potential to be designated "dual use" by the Commerce Department's Bureau of Industry and Security. Please advise us whether the referenced film-developing chemicals, which your foreign subsidiaries provide to Iran, Sudan, and/or Syria, can be used as agents or precursors for agents in chemical weapons. Please also clarify for us into which of these countries the film-developing chemicals are provided. To the best of Eastman Kodak Company's ("Kodak") management's knowledge, our non-destructive testing film developing chemicals cannot be used as agents or precursors for agents in chemical weapons. Sales of small quantities (less than $5,000 per year) of these chemicals were made by an overseas subsidiary of Kodak to civilian customers in Syria in 2005 and 2006. -----END PRIVACY-ENHANCED MESSAGE-----