December 1, 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  21,
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

Annual Report on Form 10-K for the year ended December 31, 2005

Notes to Consolidated Financial Statements, page 31
Note 1, Summary of Significant Accounting Policies, page 31
Cash and cash equivalents, page 32

Comment 1  If  amounts  in  response to our prior comment  4  that
           represent true bank overdrafts are not material, please
           clarify  your  statement  on page  32  which  indicates
           "Included in accounts payable are outstanding checks in
           excess of cash balances of $31,006,000 and $31,866,000,
           respectively"  at December 31, 2005 and  2004.   Please
           clarify  what is meant by "in excess," as your response
           indicates  that  such amounts are not bank  overdrafts,
           however, it appears as though checks payable above  the
           amount of cash on hand represents an overdraft.  Please
           advise  or revise as appropriate.  We may have  further
           comment upon receipt of your response.

Response 1 We believe the guidance in Section 1300.15 of the
           AICPA  Technical Practice Aids relating to presentation
           of  the  change  in overdrafts during  a  period  as  a
           financing   activity  only  applies  to   actual   bank
           overdraft facilities.  As we have noted below, we  have
           no  such  arrangements  with our  banks.   The  current
           disclosure's  use  of the phrase  "in  excess  of  cash
           balances"  relates  to  individual  disbursement   bank
           accounts  where checks have been mailed but  the  funds
           have  not  yet  been transferred from the main  control
           bank  account.  Funds are not transferred from the main
           control  bank  account  to the individual  disbursement
           accounts  until the checks are presented  for  payment.
           Seaboard has a legal obligation to fund the accounts at
           the  end  of  the day.  If Seaboard does not adequately
           fund  the  accounts, the checks will not be honored  by
           the  banks and will be returned to the depositor marked
           "Not-Sufficient Funds" the following day.  As a result,
           we  do  not believe we have any arrangements  with  the
           banks that would allow for a financing activity to take
           place.   Furthermore,  we  do  not  believe  that  this
           activity  meets the definition of a financing  activity
           under  SFAS  95.  In future filings, we  will  disclose
           only those amounts that are true bank overdrafts.

Note 2, Acquisitions,  Disposition  and  Repurchase  of  Minority
          Interest, page 36

Comment 2  Given  that  your  response  to  our  prior  comment  9
           discloses that SBF's EBITDA is expected to decline, and
           also, the fact that record pork prices existed in  2005
           and  are  expected to decline, please tell us  why  the
           fair value of the put option decreased.  It appears  as
           though  if  SBF is performing worse than  when  Daily's
           acquired their 4.74%, they would be more likely to  put

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           their shares back to the company in order to avoid  the
           losses expected.  Please advise.

Response 2 The sellers of Daily's have an option to put their
           4.74 percent equity interest in Seaboard Foods back  to
           Seaboard after two years for the greater of $40 million
           (floor  value) or a formula-determined value as of  the
           put  date.   The formula-determined value  was  set  to
           represent  the fair value ("FV") of Seaboard  Foods  at
           the acquisition date based on a rolling 24 month EBITDA
           calculation.   The  put  option liability  recorded  by
           Seaboard Foods at acquisition represents the calculated
           exposure  that  Seaboard  Foods  could  be  forced   to
           re-purchase  the 4.74 percent minority  interest  at  a
           price that exceeds FV at the exercise date.  This could
           happen  under  two  scenarios:  (i) the  formula  price
           falls  below the $40 million floor; or (ii) the formula
           price fails to continue to be representative of the  FV
           of  Seaboard Foods.  As long as these two scenarios  do
           not  exist,  the primary risk component is time  (i.e.,
           the longer until the exercise date, the more chance one
           of these two scenarios could develop).  As the exercise
           date  gets  closer each quarter, this time risk  factor
           decreases  and the put liability decreases accordingly.
           Again,  this  is only true as long as the  put  formula
           remains representative of FV and above the floor, which
           has been the case according to evaluations performed as
           part of the overall put option valuation calculated  by
           the  third-party specialist.  The fact that  forecasted
           EBITDA  is  declining is important to  the  put  option
           valuation because it indicates that the option is  more
           likely  to be exercised at the first available exercise
           date.  However, it did not have a significant impact on
           the  overall value of the put option liability, as  the
           expected  declines  in  pork  prices  and  EBITDA  were
           forecasted  and included in the calculation  of  FV  at
           both valuation dates.

Note 13, Segment Information, page 54

Comment 3  We note from your response to our prior comment 17 that
           you continue to believe that your major power customers
           will  pay  the past due amounts, however at a discount.
           Please   provide  us  with  your  rationale  for   your
           conclusion  given that the funding to  these  customers
           from  the  DR  government is only  for  current  energy
           production.   Include any communications you  have  had
           with  your customers which support your conclusion that
           these past due amounts will be paid.

Response 3 The receivables in question are covered under the
           terms  of two electric sector sustainability agreements
           signed   in   2004   and  early  2005   between   three
           government-owned distribution companies (two  of  which
           are the customers of Seaboard, with past due amounts in
           question),  the Dominican Republic (DR) government  and
           nine  power  generation companies, including  Seaboard.
           These  agreements  are,  in turn,  the  result  of  the
           negotiation  process  for the  broader  agreements  the
           DR   government  has  reached  with  the  International
           Monetary Fund

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           (the "IMF").  The agreements with the IMF have resulted
           in   several   letters    of   intent    for   stand-by
           agreements under which the DR government has been  able
           to  improve and stabilize the overall economy.  As  the
           DR  government  has a large presence  in  the  electric
           sector,  the  stand-by letters of intent with  the  IMF
           require that there be no default on the electric sector
           debt.  Not paying these balances would be considered an
           event  of  default  with the IMF.  The  agreements  are
           still  valid,  although specific collection  timing  is
           still  not  known.  For these reasons, we  believe  the
           amounts  are  collectible, although a discount  may  be
           required to accelerate the ultimate collection.

           Regarding   Seaboard's  two  current   customers   with
           significant past due accounts, each of these  customers
           recognizes  and  does not dispute the amounts  owed  to
           Seaboard,  as signified by the agreements noted  above.
           Collections  for the power distribution companies  have
           improved  over  the  past  year;  yet  collections  and
           pending government subsidies need to reach levels where
           they  can  remit payments to the generation  companies,
           including  Seaboard.  Prior to 2004, both of Seaboard's
           customers  in  question had paid  100  percent  of  all
           amounts invoiced since 1999, when Seaboard first  began
           to do business with them.

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,

SEABOARD CORPORATION


/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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