| 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 |
July 13, 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:
Following up on our discussion today, this letter is to confirm that we anticipate filing the material agreements in response to 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 in mid-August 2009 and filing a supplemental response letter shortly thereafter.
Sincerely,
/s/ Katherine R. Kelly
Katherine R. Kelly
Senior Counsel, Corporate Securities
Bristol-Myers Squibb Company