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.