General Motors Corporation
                                   Legal Staff
         Facsimile                                            Telephone
      (313) 665-4979                                       (313) 665-4927




March 5, 2007




Cecilia D. Blye
Chief, Office of Global Security Risk
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.  20549-5546

Dear Ms. Blye:

I am responding on behalf of General Motors Corporation ("GM" or "we") to your
letter dated January 26, 2007 commenting on my letter to the Staff dated
December 21, 2006. My December letter included a response to a supplemental
inquiry GM had received about any possible business relationship that our
affiliate Daewoo might have in North Korea or Iran and explained that GM Daewoo
Auto & Technology Company ("GMDAT") had terminated any business dealings in
locations like Iran and Sudan after purchasing certain assets from the bankrupt
Daewoo Motor Company in 2002. GM acquired a majority interest in GMDAT in 2005.

You have now asked GM to confirm that neither GM nor any of its subsidiaries or
affiliated entities has any past, present, or anticipated business relationships
or contacts with Iran, North Korea, or Sudan, except as described in our
December letter. In a telephone conversation with James Lopez of your office, we
clarified that the reference to "past" relationships was meant to cover the
period of our financial statements, beginning in 2003.

During that time GM and its subsidiaries and affiliates have had no business
relationships or contacts in North Korea, and only minimal relationships or
contacts in Iran and Sudan. From time to time subsidiaries of GM in Europe and
Asia receive inquiries from individuals or companies in Iran or Sudan about the
possibility of doing business or acquiring assets, which are consistently
declined on the advice of GM's Legal Staff and Office of Export Control. None of
these contacts was initiated by an entity related to GM. In addition, GM's
Australian subsidiary, Holden Ltd., has registered trademarks in Sudan and Iran
as part of a global program to protect its trademarks, and GM's marketing
personnel annually exchanges general market information with Toyota's
distributor in Iran, among many other contacts in other countries. Finally, in
2005, a small number of Isuzu vehicles were sold to the government of Kenya to
be used as ambulances for peace-keeping purposes in Sudan, and GM delivered
knocked-down crates and packing material to Sudan to be used for temporary
refugee shelters.






March 5, 2007
Page 2


In response to recent changes in U.S. sanctions in Sudan, GM management has
begun an evaluation of the feasibility of doing business in Southern Sudan,
which would be supported by the U.S. government. This study has not been
concluded, so that no decisions or plans have been made.

We do not believe that these matters could fairly be considered doing business
or maintaining any material relationships. The only commercial transaction that
resulted from any of these contacts was the one-time sale of a small number of
vehicles to be used in Sudan by peace-keeping forces, which should not be deemed
support for the government of Sudan as a state sponsor of terrorism. If GM
decides to enter into business in Sudan, any program would be carefully designed
and monitored to ensure compliance with all applicable requirements. If we
determine that the business or associated risks that result from a possible
program are material to GM or its stockholders, we would include appropriate
disclosure in our Annual Report on Form 10-K and other filings with the
Commission.

Please contact me at 313-665-4927 if you or your staff have any additional
questions or comments.


Sincerely,



/s/ Anne T. Larin
- -----------------
Anne T. Larin
Attorney