| Katherine R. Kelly | ||
| Vice President & Assistant General Counsel | ||
 | ||
| 345 Park Avenue New York, NY 10154-0037 | ||
| Tel 212-546-4852 Fax 212-546-9966 | ||
| katherine.kelly@bms.com | ||
| December 12, 2013 | ||
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, 2012
Filed February 15, 2013
File No. 001-01136
Dear Mr. Rosenberg:
We have received the follow-up comment letter from the staff of the Securities and Exchange Commission (the “Commission”) dated December 6, 2013 responding to Bristol-Myers Squibb Company’s response letter dated November 4, 2013, with respect to the above-referenced Form 10-K for the fiscal year ended December 31, 2012. We are submitting this letter to confirm our conversation with the staff of the Commission on December 12, 2013 regarding the timing of our response to your comments. We anticipate providing a response by January 7, 2014.
| 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