Katherine R. Kelly Vice President & Assistant General Counsel | ||||
 | 345 Park Avenue Tel 212-546-4852 | New York, NY 10154-0037 Fax 212-605-9475 | ||
| katherine.kelly@bms.com | ||||
| April 26, 2012 | ||||
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 Fiscal Year Ended December 31, 2011 Filed February 17, 2012 Form 8-K Dated January 26, 2012 Filed January 26, 2012 File No. 001-01136 | |||||||
Dear Mr. Rosenberg:
We have received the comment letter (the “Comment Letter”) dated April 19, 2012 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, 2011 and the Form 8-K dated January 26, 2012. We are submitting this letter to confirm my conversation with your colleague, Ibolya Ignat, on April 24, 2012, regarding the timing of our response to your comments. As discussed with Ms. Ignat, we anticipate providing a complete response by May 17, 2012.
| 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