UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

Mail Stop 5546
								November 16, 2006

Via Facsimile (713) 513-3499 and US Mail

Sheldon R. Erikson
President and Chief Executive Officer
Cameron International Corporation
1333 West Loop South
Suite 1700
Houston, Texas

	Re:	Cameron International Corporation
		Form 10-K for the Fiscal Year Ended December 31, 2005
      Filed March 6, 2006
      Response letter dated October 19, 2006
 		File No. 1-13884

Dear Mr. Erikson:

      We have reviewed your response dated October 19, 2006 and
have
the following comments.  Please be as detailed as necessary in
your
response.  After reviewing this information, we may raise
additional
comments.  Feel free to call us at the telephone numbers listed at
the end of this letter.

General

1. We note that certain non-U.S. subsidiaries engaged in the sale
of
oil and gas industry equipment for delivery into Sudan.  You also
state that the company`s policy for Sudan is that neither it nor
any
of its subsidiaries (including non-U.S. subsidiaries) are
permitted
to pursue or accept new business in Sudan or with any Sudanese
entity.  Please describe the transactions that resulted in sales
for
delivery into Sudan, including the dates and description of any
ongoing operations to the extent you are winding down previous
transactions or selling pursuant to previous commitments.  Please
also tell us when you adopted your current policy regarding Sudan,
and, if that policy was in effect during the Sudanese sales,
explain
whether and why sales were conducted contrary to the policy.

2. Please expand your description of sales and contacts in
connection
with Iran, Syria and Sudan to explain, to the best of your
knowledge
and belief, whether and the extent to which the governments of
these
countries, or entities controlled by them, receive financing or
otherwise act as intermediaries in connection with your sales and
contacts.

3. You state that the contacts that were the subject of the OFAC
and
BIS inquiries were the same as the Iranian contacts described in
your
letter.  Please summarize the nature and status of the OFAC and
BIS
inquiries.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please
understand
that we may have additional comments after reviewing your
responses
to our comments.  Please file your response letter on EDGAR.

      Please contact James Lopez at (202) 551-3536 if you have any
questions about the comments or our review.  You may also contact
me
at (202) 551-3470.


								Sincerely,



								Cecilia D. Blye, Chief
								Office of Global Security
Risk


cc: 	Roger Schwall
		Assistant Director
		Division of Corporation Finance


Sheldon R. Erikson
Cameron International Corporation
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