| MAURA ABELN SMITH | INTERNATIONAL PLACE III | |||
| SENIOR VICE PRESIDENT, GENERAL COUNSEL | 6400 POPLAR AVENUE | |||
| & CORPORATE SECRETARY | MEMPHIS, TN 38197 | |||
| T 901-419-3829 | ||||
| F 901-214-1248 | ||||
| maura.abelnsmith@ipaper.com | ||||
December 14, 2007
VIA Facsimile and EDGAR Correspondence
Mr. Craig Slivka
Attorney-Advisor
Division of Corporation Finance
United States Securities and Exchange Commission
One Station Place
100 F Street, N.E.
Washington, D.C. 20549
| Re: | International Paper Company |
Definitive 14A
Filed April 5, 2007
File No. 001-03157
Dear Mr. Slivka:
On behalf of International Paper Company (the “Company”), I am responding to comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission as set forth in your letter, dated November 30, 2007 (the “November Comment Letter”) relating to the above-captioned Definitive 14A. The November Comment Letter was in response to the Company’s letter, dated September 21, 2007, which in turn responded to the Staff’s comments set forth in your letter, dated August 21, 2007.
In the November Comment Letter, the Staff requested the Company to respond to the Staff’s comments by December 14, 2007, or to tell you by that time when we will provide you with a response. Accordingly, the purpose of this letter is to inform you that the Company will provide the Staff with a response on or before January 31, 2008. We trust that the Staff will let me know promptly if this response date is not acceptable for any reason.
The Company is filing this response letter via EDGAR submission in addition to providing you with a facsimile copy of the submission.
| Sincerely, |
/s/ Maura A. Smith |
| Maura A. Smith |
| Senior Vice President, General Counsel & Corporate Secretary |
| cc: | John V. Faraci |
Jerry N. Carter
William G. Walter