| Katherine R. Kelly | |||
| Senior Counsel, Corporate Securities | ||||
| 345 Park Avenue | New York, NY 10154-0037 | |||
| Tel 212-546-4852 | Fax 212-605-9475 | |||
| katherine.kelly@bms.com | ||||
| April 15, 2009 | ||||
Mr. Jeffrey Riedler
Assistant Director
U.S. Securities and Exchange Commission
Division of Corporation Finance
Washington, DC 20549
| Re: | Bristol-Myers Squibb Company |
Form 10-K for the Year Ended December 31, 2008
Filed February 20, 2009
File No. 1-01136
Dear Mr. Riedler:
We have received the letter dated April 13, 2009 regarding the comments of the staff of the Securities and Exchange Commission (the “Commission”) with respect to the above-referenced Form 10-K for the fiscal year ended December 31, 2008.
We respectfully request additional time to respond to your comments. We anticipate providing a response to you by May 11, 2009.
| Sincerely, |
/s/ Katherine R. Kelly |
| Katherine R. Kelly |
| Senior Counsel, Corporate Securities |
| Bristol-Myers Squibb Company |