May 23, 2002 Jonathan G. Katz Secretary U.S. Securities and Exchange Commission 450 Fifth Street NW Washington, DC 20549 RE: File No. S7-08-02 Abbott Laboratories Response Dear Mr. Katz: We have read the "Proposed Rule: Acceleration of Periodic Report Filing Dates and Disclosure Concerning Website Access to Reports" and have the following comments. Due to Abbott's public float and reporting history, Abbott would meet the definition of an "Accelerated Filer" under the proposed rule. In the introduction to the proposed rule, it is stated that it has been over 30 years since the filing deadlines have been changed, and that technological advancements since that time have made it easier for companies to process and disseminate information. However, the amount of information required to be included in financial statements and Management Discussion and Analysis has also greatly expanded over time. For example, the number of pages covering financial statements, notes and M,D&A in Abbott's annual reports has increased from seven pages in 1970 to 22 pages in 2001. In addition, the type of information that is now being disclosed is in addition to the basic income and cash flow statements and balance sheet. Generally speaking companies have systems and procedures in place to capture and record basic financial statement information. However, information required for footnote disclosures is usually gathered outside of the normal periodic financial statement close process. In addition, this process of gathering and summarizing this information is even more complicated for decentralized and multi-national companies. Given the above, Abbott believes that there is a potential for the quality of reporting to decrease if there is a sudden and dramatic acceleration of the required filing dates for Forms 10-K's and Forms 10-Q's. Abbott believes that a less dramatic acceleration of the filing period for a certain test period would be more appropriate. This would allow the SEC and users of the financial statements to assess the continued quality of the filings given the shortened filing period. At the end of the test period, the SEC could reassess the filing deadlines. Companies should be encouraged, however, to file at the earliest possible date, but would have the safety net of the extended filing deadlines. Very Truly Yours, Frank J. Loughery Assistant Corporate Controller Abbott Laboratories