| Katherine R. Kelly | ||
| Vice President & Assistant General Counsel | ||
 | ||
| 345 Park Avenue New York, NY 10154-0037 | ||
| Tel 212-546-4852 Fax 212-605-9475 | ||
| katherine.kelly@bms.com | ||
| May 18, 2011 | ||
VIA EDGAR
Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
| Re: | Bristol-Myers Squibb Company |
Form 10-K for the Year Ended December 31, 2010
Filed February 18, 2011
File No. 1-1136
Dear Mr. Rosenberg:
We have received the comment letter (the “Comment Letter”) dated May 4, 2011 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, 2010. We anticipate providing a complete response by June 1, 2011.
| Sincerely, |
| /s/ Katherine R. Kelly |
| Katherine R. Kelly |
| Vice President & Assistant General Counsel |
| cc: | Charles Bancroft, Bristol-Myers Squibb Company |
Sandra Leung, Bristol-Myers Squibb Company