November 15, 2006



Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3561
100 F Street, N.E.
Washington, DC 20549

Attn:   Ms. Linda Cvrkel
        Branch Chief

                         RE:  Seaboard Corporation
                              Form 10-K for the year ended December 31, 2005
                              Filed March 7, 2006
                              SEC File No. 001-03390

Dear Ms. Cvrkel:

          We are writing in response to your letter dated
November 7, 2006, with respect to the above-referenced report
filed by Seaboard Corporation ("Seaboard" or the "Company").  Our
numbered responses to your comments correspond to the numbered
comments in your letter.

          In responding to your comments, we acknowledge that:

               the Company is responsible for the adequacy and accuracy of
               the disclosure in our filing with the Commission;

               staff comments or changes to disclosure in our filing made
               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.



                   Comments and Our Responses

Comment 1   Please revise future filings to reflect the correct SEC
            mailing address of 100 F Street NE.

Response 1  In future filings, we will provide the correct SEC
            mailing address.

Comment 2   We note from your investing activities that you have
            proceeds from the sale of fixed assets.  Please tell us
            where you reflect the gains or losses on these sales in
            your consolidated statement of earnings.

Response 2  Gains or losses on sale of fixed assets are reflected
            either in cost of sales and operating expenses or in
            selling, general and administrative expenses, depending
            on the nature of the asset sold and where the
            depreciation associated with the asset was previously
            reflected.  For example, if an asset was depreciated as
            a component of cost of sales, then any gain or loss on
            sale of this asset is reflected in cost of sales.

Comment 3   We note the disclosure indicating that revenue of the
            containerized cargo service is recognized ratably over
            the transit time for each voyage.  Please tell us and
            explain in the notes to your financial statements in
            future filings, how the expenses associated with your
            containerized cargo service are recognized in your
            financial statements.  As part of your response, you
            should explain how the treatment used complies with the
            guidance outlined in EITF 91-9.

Response 3  In accordance with method 5 of EITF 91-9, the
            allocation of revenue from our containerized cargo
            service between reporting periods is based on relative
            transit time in each reporting period, with expenses
            associated with our containerized cargo service being
            recognized as incurred.  In the notes to our financial
            statements contained in future filings, as appropriate,
            we will explain that expenses associated with our
            containerized cargo service are recognized as incurred.

Comment 4   We note the disclosure indicating that outstanding
            checks in excess of cash balances of $31,006,000 and
            $31,866,000, respectively at December 31, 2005 and 2004
            have been included in accounts payable.  We further
            note that changes in accounts payable have been
            reflected as an operating cash flow in your statements
            of cash flows for these periods.  Please revise to
            reflect the changes in outstanding checks in excess of
            cash balances at these dates, which are essentially
            bank overdrafts, as cash flows from financing
            activities.  Refer to the guidance outlined in section
            1300.15 of the AICPA Technical Practice Aids.

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Response 4  Seaboard utilizes various disbursement accounts in its
            world-wide cash management process.  At the time checks
            are presented for payment, the funds are deposited into
            the disbursement accounts.  Substantially all of the
            amounts disclosed under "Cash and Cash Equivalents" in
            Note 1 to our consolidated financial statement,
            constituted outstanding checks which had not been
            presented for payment at the balance sheet date.
            Considering that the related banking institutions have
            not funded these checks, we do not consider such
            amounts to constitute a financing activity.  The actual
            amount of true bank overdrafts (where banking
            institutions have advanced funds) at the end of our
            2005, 2004 and 2003 fiscal years were $59,000, $0,
            $483,000, respectively.  We do not believe that such
            amounts are material to the Company and, so long as any
            such bank overdrafts are not material, we do not
            believe it is necessary to classify such amounts as
            cash flows from financing activities in the cash flow
            statement.

Comment 5   Please provide us with further details on the nature of
            your deferred grant revenue.  If such funds received
            were contributed by government entities for the
            construction of hog processing facilities, tell us why
            you did not classify these amounts as reimbursement of
            your capital expenditures rather than revenue.

Response 5  In fiscal years 1994 through 1996, Seaboard accounted
            for these grants received from government entities as a
            form of construction financing.  In the Annual Reports
            for these years, Seaboard showed the grant monies as a
            financing cash inflow and the expenditures on the
            processing facility as an investing cash outflow.
            Since that time, amounts amortized are directly offset
            with depreciation of the processing facility within
            cost of sales and thus have the same effect on the
            statement of earnings and cash flow statement as if
            such amounts had been initially classified as a
            reimbursement of our capital expenditures.  In future
            filings, as appropriate, we will revise the note to our
            consolidated financial statements to make this more
            clear by changing the current wording of the last
            sentence under "Deferred Grant Revenue" in Note 1 to
            our consolidated financial statements to read as
            follows:

                 "Deferred grants are being amortized as a
                 reduction of depreciation expense over the life of
                 the assets acquired with the funds."

            We also will no longer use the word "revenue" in the
            notes to our consolidated financial statements when
            referring to the deferred grants.

Comment 6   We note from MD&A, page 19, that foreign currency
            fluctuations primarily relate to fluctuations in the
            value of the Dominican Republic peso compared to the
            U.S. dollar.  Please explain in detail, your accounting
            for such transactions and translations given that the
            Dominican Republic is considered a highly inflationary
            economy under the definition in SFAS 52.  It appears to
            us as though the functional currency of your power
            segment

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            should be the U.S. dollar rather than the DR
            Peso.  Please confirm to us that this is the case if
            not, tell us why.

Response 6  The functional currency for the Dominican Republic
            ("DR") power business is the U.S. dollar.  The foreign
            currency gains or losses are generated as the majority
            of accounts receivable are actually DR peso denominated
            along with certain other current assets and current
            liabilities.  As the DR peso fluctuates, the U.S.
            dollar amount that Seaboard will receive or pay, as
            applicable, fluctuates and results in currency gains or
            losses at month-end when valuing the balance sheet in
            terms of equivalent U.S. dollars.

Comment 7   Please provide us with further details concerning the
            nature of the "working capital adjustments" of
            $3,098,000 given as part of the consideration in the
            acquisition of Daily's.

Response 7  Under the Sale and Contribution Agreement between
            Seaboard and Daily's, the consideration paid was based
            on valuations of both companies using results through
            December 31, 2004.  As such, the December 31, 2004
            working capital balances of both companies were
            established, with certain agreed-upon adjustments, as
            the "assumed working capital balances" to be acquired
            in the transaction.  To the extent these working
            capital balances changed between December 31, 2004 and
            the July 3, 2005 effective date of the acquisition,
            that change was treated as an adjustment to the
            purchase price.  Daily's net working capital was higher
            at the effective date than at December 31, 2004,
            resulting in additional amounts due under the
            agreement.

Comment 8   Please explain in detail how the fair value of the
            4.74% equity interest in Seaboard Foods L.P. that was
            issued as partial consideration for the acquisition of
            Daily's was determined and explain why recording the
            excess of fair value over your cost basis in additional
            paid in capital is considered appropriate.  We may have
            further comment upon receipt of your response.  Also,
            revise future filings to disclosure your accounting
            policy with respect to sale or other exchanges of
            subsidiary stock.  Refer to the guidance outlined in
            SAB Topic 5.H.

Response 8  The fair value of the 4.74% equity interest in Seaboard
            Foods L.P. ("SBF") was determined by the negotiated
            calculation and agreed to by both parties as being
            representative of fair value of the equity interest of
            taking the two year (2003 and 2004) EBITDA average of
            both Daily's and SBF times an earnings multiple for
            each company.  The individual value of Daily's as a
            percentage of the total combined business value was
            then split equally between cash and stock in SBF to
            arrive at the 4.74% interest.  The value of the 4.74%
            interest was validated by a third party valuation
            specialist who also compared these earnings multiples
            to other similar industry transactions and related
            market multiples.

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            Seaboard recorded the excess of fair value over our
            cost basis as additional paid-in capital based on
            guidance outlined in SAB Topic 5.H.  In its
            interpretive response to Question 2 in SAB Topic 5.H,
            the staff has objected to gain recognition in certain
            circumstances.  Specifically, "The staff believes that
            gain recognition is not appropriate in situations where
            subsequent capital transactions are contemplated that
            raise concerns about the likelihood of the registrant
            realizing that gain such as . reacquisition of shares
            is contemplated at the time of purchase.  The staff
            will presume that repurchases were contemplated at the
            date of issuance in those situations ... where a
            specific plan existed to repurchase shares at the time
            shares were issued."  The interpretive response goes on
            to say, "In those situations, the staff believes that
            the change in the parent company's proportionate share
            of subsidiary equity resulting from the additional
            equity raised by the subsidiary should be accounted for
            as an equity transaction in consolidation.  Gain
            deferral is not appropriate."  Accordingly, Seaboard
            believes it was appropriate to record the excess fair
            value over the cost basis as additional paid-in capital
            instead of as a gain as a result of  the existence of
            the put and call options on this equity.

            Because Seaboard has not yet had any other similar
            transactions involving the sale of subsidiary stock and
            because gain recognition or deferral is not appropriate
            for this situation, we believe that disclosure of our
            accounting policy with respect to sale or exchanges of
            subsidiary stock as outlined in SAB Topic 5.H is not
            required and would not be meaningful at this time.

Comment 9   Please tell us and revise Note 2 to explain in detail
            how you calculated or determined the fair values of the
            put and call options associated with the 4.74% equity
            interest in Seaboard Foods, LP.  Also, tell us and
            explain in the notes to your financial statements the
            facts or circumstances that resulted in the $1,300,000
            decrease in the fair value of the put option obligation
            through December 31, 2005.

Response 9  The fair value of the put option associated with the
            4.74% was determined by a third party valuation
            specialist using the Black Scholes call option pricing
            model, which considered such factors, as inputs to the
            model, term, interest rate, volatility and estimated
            future cash flows of SBF (affecting fair value and
            strike price inputs).  The existence of SBF's call
            option was considered in the appraisal as a factor that
            could affect the expected exercise of the put option;
            but no amounts were recognized by Seaboard for the call
            option.

            In addition, each quarter, Seaboard has the third party
            valuation specialist update its report to determine the
            change in valuation of the put option based on any
            changes to the related factors that affect the inputs
            to the option-pricing model, including estimated cash
            flows of SBF.  The SBF EBITDA is expected to decline
            after 2005 because management has reflected the
            cyclicality of the pork industry in their projections.
            Pork commodity prices were at or near all-time highs
            during

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            2005.  Management expects pork selling prices
            and EBITDA to decline as a result of expected cyclical
            downturns in the industry.  As a result, the fair value
            of the put option decreased $1,300,000.

            In future filings, as appropriate, we will explain in
            the notes to our financial statements the facts or
            circumstances that resulted in the decrease in the fair
            value of the put option obligation.

Comment 10  Please revise Note 2 to disclose the factors that
            contributed to a purchase price that resulted in the
            recognition of goodwill.  Refer to the disclosure
            requirements outlined in paragraph 51b of SFAS No. 141.

Respone 10  The factors that contributed to a purchase price that
            resulted in the recognition of goodwill were (i) the
            expansion of Pork's integrated model into value-added
            products allowing further realization from Pork's
            existing products and enhancing Pork's ability to
            venture into other further processed pork products and
            (ii) access to an expanded base of industry knowledge
            and expertise.  In future filings, as appropriate, we
            will revise Note 2 to highlight these factors as the
            factors which contributed to the Goodwill.

Comment 11  Please tell us and revise the notes to your
            financial statements to explain the facts or
            circumstances that resulted in an increase in the
            deferred tax asset valuation allowance of approximately
            $18.3 million during 2005.

Response 11 The 2005 increase of $18.3 million in the deferred tax
            asset valuation was the result of additional capital
            losses and additional foreign deferred tax assets which
            management does not believe are more likely than not to
            be realized (due to the Company's sizable capital loss
            carryforward and foreign net operating losses (NOLs) in
            certain countries). Specifically, the change in
            valuation allowance was composed of the following
            pieces: $2.5 million of additional capital losses upon
            the 2005 settlement of an IRS examination, $1.8 million
            of additional losses during 2005 on foreign investments
            that will be recognized as capital losses, and $14.0
            million resulting from changes in 2005 to foreign
            deferred tax assets primarily related to foreign NOLs.

            In future filings, as appropriate, we will revise the
            notes to our consolidated financial statements to
            include the following disclosure: "The increase in the
            valuation allowance for 2005 was the result of
            additional capital losses and additional foreign
            deferred tax assets, which management does not believe
            are more likely than not to be realized.

Comment 12  We note that PIC has declined to provide
            indemnification with regard to some matters and has
            agreed to indemnification with regard to other matters
            up to $5 million.  Please tell us, and revise future
            filings to disclose, the amounts you believe you will
            be required to spend to remediate the problems

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            identified by the EPA and state of Oklahoma, the
            amounts for which PIC has accepted liability, amounts
            you then believe you will be required to pay, including
            items for which you may dispute indemnification with
            PIC and include all amounts you have accrued as
            liabilities on your balance sheet related to these
            actions.  If you have not accrued any liabilities,
            please tell us why.  Refer to SFAS 5.

Respone 12  In Note 11 to our consolidated financial statements
            filed with our 10-K Annual Report for the year ended
            December 31, 2005, we disclosed that the estimated
            cumulative costs which will be expended will total
            approximately $6,900,000.  In Note 5 to our
            consolidated financial statements filed with our 10-Q
            Report for the quarter ended September 30, 2006, we
            updated this estimate, stating that the amounts
            expended to date and the estimated cumulative future
            capital expenditures total approximately $7,600,000.
            This is the amount we have estimated it will cost on a
            cumulative basis for capital expenditures, remediation
            and legal expenses incurred to date, in addition to the
            penalty of $240,000 agreed to with EPA and the penalty
            of $100,000 paid to the State of Oklahoma.  In future
            filings, as appropriate, we will modify our disclosure
            to state that the estimate includes the costs of
            remediation.

            To date, PIC has declined to reimburse us for the
            $100,000 penalty paid to the State of Oklahoma and has
            indicated that it may not pay more than $5,000,000 in
            the aggregate, of the $7,600,000 estimated expenditures
            and the $240,000 penalty agreed to with EPA.  If PIC
            does not pay the estimated expenditures and penalties
            in excess of $5,000,000, then Seaboard could be
            responsible to pay an estimated $2,840,000. In future
            filings, as appropriate, we will modify our disclosure
            to explain that if PIC does not pay the estimated
            expenditures and penalties in excess of $5,000,000,
            then Seaboard could be responsible to pay an estimated
            $2,840,000.

            We have not accrued any amount of liability on our
            balance sheet because we do not deem that it is
            "probable" pursuant to SFAS 5 that PIC is not
            responsible to indemnify us for the entire amount of
            the expenditures and EPA penalty.

Comment 13  In a related matter, please tell us why, given
            your disclosure that Seaboard Marine received a notice
            of violation from the U.S. Customs and Border
            Protection demanding a "significant penalty," you
            believe the resolution of this matter will not have any
            material adverse effect on the financial position of
            Seaboard.

Response 13 It is our belief that, based on the facts of the
            matter, the relevant statutory and regulatory
            provisions  and the US Customs Mitigation Factors, we
            will be able to significantly mitigate the penalty, or
            eliminate it, such that the matter will not have any
            material adverse effect on our financial position.  In
            particular, 19 U.S.C.  1584(a)(2) provides that there
            is no liability if we did not know, and

 7

            could not, through the exercise of the highest degree
            of care and diligence, have known, there were narcotics
            on the vessel.  In addition, the Mitigation Guidelines
            provide that in the event we did not have any actual
            knowledge of the narcotics, but were grossly negligent,
            the assessed penalty is to be reduced to 25% to 50% of the
            assessed penalty, and in the event we were not grossly
            negligent, but were negligent, the assessed penalty is
            to be reduced to 10% to 25% of the assessed penalty.

Comment 14  The second to last paragraph in note 11 discloses
            incentive payments to contract farmers payable upon
            achievement of certain performance standards.  Please
            tell us what amounts you have historically paid under
            such agreements for incentive payments and amounts
            accrued at December 31, 2005 related to these
            contracts.  If you have not accrued these payments,
            please tell us why you do not believe these obligations
            are probable and provide us with the rationale for your
            conclusion.  Please refer to SFAS 5.

Response 14 Historically, incentive payments to contract farmers
            were $1.3 million, $0.8 million and $0.3 million for
            the years ended December 31, 2005, 2004 and 2003,
            respectively.  These incentive payments pertain to the
            finisher phase of the hog production cycle and are not
            payable until such hogs have been delivered to the
            plant for processing (a "close out").  Based on
            historical performance, not all farmers achieve these
            incentives on each close out.  No amounts were accrued
            for these payments as of December 31, 2005, other than
            for those amounts in process to be paid as a result of
            a recent close out, as such amounts are not deemed
            material.  We anticipate paying out approximately
            $1.5 million annually related to incentive payments
            given current operating performance, or approximately
            $29,000 per week.  At period end, we estimate that
            approximately nine weeks of payments could be
            considered and would total approximately $260,000.  The
            offsetting debit would be to increase inventory and is
            not material, compared to total inventories of $331.1
            million as of December 31, 2005.  The only statement of
            earnings effect question could be to the extent a
            grower group closed out and went through cost of sales
            before period end and the efficiency payment was made
            after period end.  It takes Seaboard approximately 2-3
            weeks after a close out to make this payment so that
            could be $58,000 to $87,000 paid "out of period".  Such
            amount is not deemed material to the financials
            statements of Seaboard.

Comment 15  We note your disclosure from page 14 regarding
            potential additional EPA claims.  Please tell us why
            you have not discussed these claims in the notes to
            your financial statements in accordance with SFAS 5.
            Also, please provide us with further details regarding
            your conclusions that management believes the emissions
            from its hog operations do not require CAA permits.
            Include in your response any updates since the filing
            of your financials statements

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            with regards to this case and any amounts accrued in your
            financial statements. If you have no amounts accrued,
            please tell us why.

Response 15 We disclosed the potential additional EPA claims in
            Item 3. Legal Proceedings, to our 10-K because this
            item requires disclosure of any environmental
            administrative proceedings when the potential monetary
            sanctions are $100,000 or more.  This threshold is met
            with respect to the matter disclosed.  We did not
            disclose this matter in the notes to our consolidated
            financial statements because the potential exposure is
            not material.

            Our conclusion that our hog operations do not require
            CAA permits is based on the conclusions of a technical
            consultant who conducted a "mass balance analysis" with
            respect to the emissions.  In Part II-Other Information
            Item 1. Legal Proceedings of our Form 10-Q report for
            the quarter ended September 30, 2006, we disclosed that
            we had entered into a Consent Decree with the United
            States to settle the matter, pursuant to which Seaboard
            Foods agreed to pay a civil penalty of $205,000 and to
            take various other actions which will cost
            approximately $150,000, and that this Consent Decree is
            subject to court approval.  We have paid $100,000 of
            the $205,000 agreed civil penalty and have accrued a
            liability for the remaining $105,000.  No liability has
            been accrued for the $150,000 estimated amount to be
            incurred to take other actions because these
            expenditures will result in capital improvements.

Comment 16  We note the disclosure in Note 12 indicating that
            the 6313.34 shares issued to the Company's parent
            company during 2005 were included in the weighted
            average number of shares used to compute basic earnings
            per share for one day in the third quarter and the
            entire period in the fourth quarter and for the entire
            third and fourth quarter for purposes of calculating
            the weighted average number of shares used to compute
            diluted earnings per share.  Please explain in detail
            why you believe it was appropriate to include these
            shares in the weighted average shares used to compute
            diluted earnings per share for the entire third quarter
            of 2005.  We may have further comment upon receipt of
            your response.

Response 16 The number of shares to be issued to Seaboard Flour
            were contingent upon Seaboard Corporation's ability to
            utilize certain NOLs.  The conditions necessary to
            trigger the utilization of these NOLs were not attained
            and maintained until the third quarter of 2005.
            Therefore, in the third quarter of 2005, Seaboard
            included the shares issued in the weighted average
            shares used to compute diluted earnings per share for
            the entire third quarter of 2005 based on paragraph 30a
            of Statement of Financial Accounting Standards No. 128,
            Earnings per Share.  Paragraph 30a states that, "Shares
            whose issuance is contingent upon the satisfaction of
            certain conditions shall be considered outstanding and
            included in the computation of diluted EPS ... if all
            necessary conditions have been satisfied by the end of
            the period, those shares shall be included as of the
            beginning of the period in which

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            the conditions were satisfied."  The 6,313.34 shares
            became outstanding as of the last day of the third
            quarter and therefore, to compute diluted earnings per
            share, the entire period of the third quarter was used.

Comment 17  We note from the fourth paragraph on page 55 that
            $13,620,000 remains outstanding from customers with
            past due balances in your power segment.  We further
            note from MD&A, page 17, that it is uncertain if
            Seaboard will be fully able to collect these amounts.
            Please tell us what amounts you have reserved in your
            allowance for doubtful accounts, how you determined
            these amounts and why you believe you will collect
            amounts for which a related allowance has not been
            established.

Response 17 The total reserve amount as of December 31, 2005 was
            $1,764,798 for customers with past due balances in our
            power segment primarily related to three large
            customers, each accrued at approximately 15% of their
            total outstanding balance past due.  This percentage
            was arrived at based on management's best estimate as
            to the ultimate collection which is likely to be at a
            discount from the original amount billed based on the
            aging of the account.  History has proven our ability
            to collect substantially all recognized amounts past
            due from our customers.  For one of these large
            customers, some payments were received during 2005 and
            subsequently during 2006 this account has been fully
            collected.  The other two large customers are owed
            monies from the DR government and the past due amounts
            represents a DR power industry-wide agreement to freeze
            receivables related to 2004, which is primarily the
            amount classified as a long-term asset.

            While the DR government had initially proposed that
            current production and accruing interest would be paid
            in full during 2005 while a one-year moratorium was
            imposed on the old past-due principal balances, no plan
            has been put in place and the government has only
            funded the payment of current energy production.
            Currently, Seaboard believes the remaining amounts due
            will ultimately be collected from the specific
            customers based on future payments from the DR
            government but at some discount factor currently
            estimated at 15% by management.

Comment 18  Please address our comments on your Annual Report
            on Form 10-K in your Quarterly Reports on Form 10-Q,
            where applicable.

Response 18 We will address your comments, as applicable, in our
            Annual Report on Form 10-K for the year ending December
            31, 2006 and in our future Quarterly Reports on Form 10-Q.

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            We hope that the above has been of assistance to you
and that it is fully responsive to your comments.  If you have
any questions or require any further information, please call me
at (913) 676-8833 or John Virgo at (913) 676-8936.

                              Very truly yours,


                              /s/Robert L. Steer

                              Robert L. Steer
                              Senior Vice President, Treasurer
                              and Chief Financial Officer


cc:  Ms. Heather Tress
     Steve Bresky
     John Virgo
     David Becker

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