[Wyeth Letterhead]

February 8, 2008

Tim Buchmiller, Esq.

Senior Attorney

Division of Corporation Finance

Mail Stop 6010

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:	Wyeth
	Definitive Proxy Statement
	Filed March 16, 2007
	File No. 1-1225

Dear Mr. Buchmiller:

Wyeth (the “Company”) acknowledges receipt of the comment of the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) set forth in a letter from the Staff dated January 16, 2008 (the “Comment Letter”) pertaining to the Company’s 2007 Definitive Proxy Statement filed on March 16, 2007.

Set forth below is the Company’s response to the Staff’s comment. To assist in your review, we have retyped the text of the Staff’s comment in italics below.

1. We note your response to prior comment 12. We continue to believe that your annual cash incentive awards should be disclosed in your table pursuant to Item 402(d)(2)(iii) of Regulation S-K. Your summary compensation table, which includes amounts under the “non-equity incentive plan compensation” column, and your responses to prior comments 9 and 12, each appear to indicate that the Executive Incentive Plan meets the definition of a non-equity incentive plan as defined in Item 402(a)(6)(iii) of Regulation S-K. Please confirm that in future filings you will provide the information required by Item 402(d)(2)(iii) in the Grants of Plan-Based Awards table. If you believe the target amounts are not determinable, then you should provide a representative amount based on the previous fiscal year’s performance. See Instruction 2 to Item 402(d) of Regulation S-K. To the extent you believe that the maximum amounts do not fairly represent the potential amounts payable under the plan, you should consider providing narrative or footnote disclosure explaining the intended role of the putative maximum amounts.

Response:

The Company acknowledges the Staff’s comment and will include the requested disclosure in its 2008 proxy statement.

* * * * *

We appreciate the willingness of the Staff to work with us to achieve the desired compliance with applicable disclosure regulations.

Please let us know if you have any additional comments or questions by contacting Bryan Supran, Assistant General Counsel – Corporate, at (973) 660-5722 or Tara Gabbai, Corporate Counsel, at (973) 660-5835.

Very truly yours,

Wyeth

By:	/s/ Bryan A. Supran
	Bryan A. Supran
	Assistant General Counsel – Corporate
cc:	Mr. Robert Essner
	Chairman of the Board
	Mr. Bernard Poussot
	President and Chief Executive Officer
	Mr. Gregory Norden
	Senior Vice President and Chief Financial Officer
	Mr. Lawrence V. Stein
	Senior Vice President and General Counsel
	Ms. Denise M. Peppard
	Senior Vice President – Human Resources
	Ms. Eileen M. Lach
	Vice President, Corporate Secretary and Associate General Counsel

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