UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

Mail Stop 5546
								March 30, 2007


Via Facsimile (512) 283-2836 and US Mail

Michael S. Dell
Chief Executive Officer
Dell Inc.
One Dell Way,
Round Rock, Texas 78682

	Re:	Dell Inc.
		Form 10-K for the Fiscal Year Ended February 3, 2006
      Filed March 15, 2006
 		File No. 0-17017

Dear Mr. Dell:

      We have limited our review of the above filing to
disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and we will make no further review of
the filing.  Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues.  At this juncture, unless otherwise directed, we are
asking
you to provide us with supplemental information so that we may
better
understand your disclosure.  Please be as detailed as necessary in
your response.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General
1. We note from your website and public reports that some of your
products are available, and may be formatted for use, in Cuba,
Iran,
North Korea, Syria and Sudan.  Each of these countries is
identified
as a state sponsor of terrorism by the State Department and
subject
to U.S. economic sanctions and export controls.  Your Form 10-K
does
not contain disclosure of activities associated with Cuba, Iran,
North Korea, Syria or Sudan.  Please describe your current, past
and
anticipated operations in and contacts with such countries, if
any,
including through distributors and other direct and indirect
arrangements.  Tell us whether, and explain the extent to which,
the
governments of Cuba, Iran, North Korea, Syria and Sudan, or
entities
controlled by them, receive financing or act as intermediaries in
connection with any such operations.
2. Discuss the materiality to you of the operations and contacts
described in your response to the foregoing comment, in light of
the
countries` status as state sponsors of terrorism.  Please also
discuss whether the operations or contacts constitute a material
investment risk to your security holders.
3. Your materiality analysis should address materiality in
quantitative terms, including the approximate dollar amount of
your
revenues, assets and liabilities associated with Cuba, Iran, North
Korea, Syria and Sudan.  Please also address materiality in terms
of
qualitative factors that a reasonable investor would deem
important
in making an investment decision, including the potential impact
of
corporate activities upon a company`s reputation and share value.

We note, for example, that Arizona and Louisiana have adopted
legislation requiring their state retirement systems to prepare
reports regarding state pension fund assets invested in, and/or
permitting divestment of state pension fund assets from, companies
that do business with countries identified as state sponsors of
terrorism.  The Missouri Investment Trust has established an
equity
fund for the investment of certain state-held monies that screens
out
stocks of companies that do business with U.S.-designated state
sponsors of terrorism.  We note also that Vermont`s Pension
Investment Committee has adopted a resolution restricting
investments
in companies and governments linked to terrorist or genocidal
activities.  California, Connecticut, Illinois, Maine, Oregon and
New
Jersey have adopted, and other states are considering, legislation
prohibiting the investment of certain state assets in, and/or
requiring the divestment of certain state assets from, companies
that
do business with Sudan.  Harvard University, Stanford University,
Yale University, the University of California and other academic
institutions have adopted policies prohibiting investment in,
and/or
requiring divestment from, companies that do business with Sudan.
Your materiality analysis should address the potential impact of
the
investor sentiment evidenced by such actions concerning companies
with operations associated with Cuba, Iran, North Korea, Syria and
Sudan.
4. Please also address the impact of your regulatory compliance
programs that cover operations and contacts associated with these
countries, and any internal risk assessment undertaken in
connection
with business in those countries.  In this regard, please address
the
applicability to your Iran-related activities, including any
direct
or indirect payments to the Iranian government, of Section 5(b) of
the Iran Sanction Act of 1996, as modified by the Iran Freedom
Support Act on September 30, 2006.


      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please
understand
that we may have additional comments after reviewing your
responses
to our comments.  Please file your response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filing; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.


      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      Please contact James Lopez at (202) 551-3536 if you have any
questions about the comments or our review.  You may also contact
me
at (202) 551-3470.


								Sincerely,



								Cecilia D. Blye, Chief
								Office of Global Security
Risk


cc: 	Barbara Jacobs
		Assistant Director
		Division of Corporation Finance


Michael S. Dell
Dell, Inc.
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