Securities Exchange Act of 1934
Rule 14a-8

March 29, 2007

Michael A. Stanchfield
Faegre & Benson LLP
2200 Wells Fargo Center
90 South Seventh Street
Minneapolis, MN 55402-3901

Dear Mr. Stanchfield:

This is in regard to your letter dated March 23, 2007 concerning the shareholder proposal submitted by California Public Employees' Retirement System for inclusion in UnitedHealth Group's proxy materials for its upcoming annual meeting of security holders. Your letter indicates that UnitedHealth Group will include the proponent's revised proposal in its proxy materials, and that UnitedHealth Group therefore withdraws its January 11, 2007 request for a no-action letter from the Division. Because the matter is now moot, we will have no further comment.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/2007/
uhg032907-14a-8.htm