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

         DIVISION OF
CORPORATION FINANCE

Mail Stop 5546
								September 13, 2006

Via Facsimile (713) 513-3499 and US Mail

Sheldon R. Erikson
President and Chief Executive Officer
Cameron International Corporation
1333 West Loop South
Suite 1700
Houston, Texas

	Re:	Cameron International Corporation
		Form 10-K for the Fiscal Year Ended December 31, 2005
      Filed March 6, 2006
 		File No. 1-13884

Dear Mr. Erikson:

      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.

1. We note from media reports and your risk factor "The Company`s
international operations expose it to instability and changes in
economic and political conditions ..." incorporated from your
annual
report that you may have operations in Iran, a country identified
as
a state sponsor of terrorism by the State Department and subject
to
sanctions administered by the Commerce Department`s Bureau of
Industry and Security and the Treasury Department`s Office of
Foreign
Assets Control.  We also note media reports that you took steps in
2005 to sever business ties with Iran.  Your Form 10-K discloses
that
you have operations in the Middle East and Africa but, apart from
the
risk factor, does not contain information relating specifically to
operations in or contacts with Iran.  Please describe your
current,
past and anticipated operations in and contacts with Iran and any
other African or Middle Eastern countries identified by the State
Department as state sponsors of terrorism, including through
subsidiaries, affiliates and other direct and indirect
arrangements.
Include in your response a description of the contacts that are
the
focus of the OFAC and Commerce Department inquiries mentioned in
the
referenced risk factor.

2. Discuss the materiality to you of the operations and contacts
described in your response to the foregoing comment, in light of
the
related 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
revenues, assets and liabilities associated with Iran and any
other
state sponsor of terrorism.  Please 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 your reputation and share value.

For example, we note 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 the Pennsylvania
legislature has adopted a resolution directing its Legislative
Budget
and Finance Committee to report annually to the General Assembly
regarding state funds invested in companies that have ties to
terrorist-sponsoring countries.  Your materiality analysis should
address the potential impact of the investor sentiment evidenced
by
such actions directed toward companies operating in Iran and other
countries identified as state sponsors of terrorism.

Please also address the impact of your regulatory compliance
programs, such as programs designed to prevent terrorism funding,
which cover operations and contacts associated with these
countries,
and any internal risk assessment undertaken in connection with
business in those countries.

      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: 	Roger Schwall
		Assistant Director
		Division of Corporation Finance


Sheldon R. Erikson
Cameron International Corporation
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