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                     SEABOARD CORPORATION


July 13, 2011


Justin Dobbie
Legal Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC  20549


RE:  Seaboard Corporation
     Form 10-K
     Filed March 9, 2011
     Definitive Proxy Statement on Schedule 14A
     Filed March 15, 2011
     Form 10-Q
     Filed May 6, 2011
     File No. 001-03390


Dear Mr. Dobbie:

We are writing in response to your letter dated July 1, 2011,
with respect to the above-referenced report filed by Seaboard
Corporation ("Seaboard" or the "Company").  Our numbered
responses to your comments correspond to the numbered comments in
your letter.

In responding to your comments, we acknowledge that:

     -    the  Company  is  responsible  for  the  adequacy  and
          accuracy of  the  disclosure  in  our  filing with the
          Commission;

     -    staff comments or changes to disclosure in response to
          staff  comments  do  not foreclose the Commission from
          taking any action with respect to the filing; and

     -    the Company may not assert staff comments as a defense
          in  any proceeding  initiated by the Commission or any
          person under the federal securities laws of the United
          States.

<PAGE>


                   COMMENTS AND OUR RESPONSES


Form 10-K

Item 1A: Risk Factors, page 7

Comment 1:   Please delete the phrase "but are not limited to" in
             future filings. Your "Risk Factors" section should
             include all material risks.

Response:    In future filings, we will delete the phrase as
             requested and we confirm our "Risk Factors" section
             will continue to include all material risks.

Management's Discussion and Analysis
- Contractual Obligations and Off-Balance Sheet Arrangements,
page 16

Comment 2:   We note that your disclosure in MD&A includes a table
             of contractual obligations. In future filings, please
             include disclosure of long-term liabilities presented
             on your balance sheet such as pension liabilities and
             deferred tax liabilities. See Item 303(A)(5) of
             Regulation S-K.

Response:    In future filings, as appropriate we will add a
             separate line item titled "other long-term
             liabilities" with the related disclosure to the table
             of contractual obligations substantially to the
             following effect :

             "Other long-term liabilities in the table above
             represent expected benefit payments for various non-
             qualified pension plans and supplemental retirement
             arrangements as discussed in Note 10 to the
             Consolidated Financial Statements, which are deemed
             to be employer contributions since these are unfunded
             obligations.  No contributions are planned at this
             time to the two qualified pension plans.   Non-
             current deferred income taxes and certain other long-
             term liabilities on the Consolidated Balance Sheet
             are not included in the table above as management is
             unable to reliably estimate the timing of the
             payments for these items.  In addition, deferred
             revenues included in other long-term liabilities on
             the Consolidated Balance Sheet have been excluded
             from the table above since they do not represent
             contractual obligations."

Statements of Earnings, page 29

Comment 3:   We note that revenue is presented as "net sales" on
             the face of the statements of earnings.  Please
             explain to us, and disclose in future filings, the
             nature of any incentives, discounts or allowances
             that are recorded as reductions to revenue in the
             calculation of the "net sales" amount. Please also
             disclose the accounting policy and when these items
             are recognized in the financial statements. To the
             extent that the aggregate amount of reductions to
             gross revenue are material,

<PAGE> 2

             please disclose the amount of the reductions in the
             notes to the financial statements in future filings,
             preferably by individual components in tabular format.

Response:    Seaboard records revenue net of certain items, which
             primarily include estimated discounts based on volume
             recognized at the time of sale.  The aggregate amount
             of reductions to revenue as a percentage of net sales
             is less than 1%.  Accordingly, Seaboard has deemed
             these amounts immaterial for disclosure purposes but
             will include in future filings if such amounts become
             material.

Notes to the Financial Statements

Note 2. Investments

Comment 4:   We note from your disclosure in the statement of cash
             flows that during each of the years in which a
             statement of earnings has been provided you have
             received proceeds from the sale of short-term
             investments and the maturity of short-term
             investments. Please revise future filings to include
             the disclosures required by ASC 320-10-50-9 which
             include disclosure of the gross realized gains and
             gross realized losses that have been included in
             earnings as a result of the sales of available for
             sale securities.

Response:    Pretax gross realized gains on the sale of available
             for sale securities as a percentage of earnings
             before income tax were 1.5%, 0.6% and 2.2% for the
             years ended December 31, 2010, 2009 and 2008,
             respectively. Pretax net realized gains on the sale
             of available for sale securities as a percentage of
             earnings before income tax were 1.4%, 0.2% and 1.8%
             for the years ended December 31, 2010, 2009 and 2008,
             respectively.  Accordingly, Seaboard has deemed these
             amounts immaterial for disclosure purposes.  Seaboard
             will include the disclosures required by ASC 320-10-
             50-9 in future filings, if such amounts are material.

Note 13. Segment Information, page 55

Comment 5:   We note your disclosure that on March 2, 2009 an
             agreement became effective under which you will sell
             two floating power generating facilities in the
             Dominican Republic for $70 million and as of December
             31, 2010 the net book value of the two barges was
             $20.1 million and are classified as held for sale on
             the balance sheet. We further note your disclosure
             that you expect to recognize a gain on the sale of
             assets of approximately $50 million in operating
             income at the close of the sale in 2011. Please
             explain to us why believe that this sale
             appropriately represents the sale of assets rather
             than a discontinued operation. As part of your
             response, please explain to us whether these power
             generating facilities represent a component of an
             entity. Please see the guidance in ASC 205-20-45.

<PAGE> 3

Response:    The power barges sold represent individual assets at
             a level below that of a component of an entity.  The
             power barges sold were used together with other
             assets including fuel storage tanks, line connections
             to the local power grid and other assets which
             collectively are considered the power generating
             component.  Seaboard has retained this component to
             continue as a supplier to the Dominican power grid
             after this sale.    As discussed below, Seaboard is
             removing certain older assets and replacing them with
             similar new, more efficient assets at the same
             location to continue to produce power and therefore
             did not meet the criteria for discontinued operations
             in ASC 205-20-45.  This is akin to retrofitting a
             plant with new equipment.

             Seaboard first disclosed the agreement to sell the
             two floating generating facilities in the Dominican
             Republic in its 2008 Annual Report on Form 10-K.  It
             is important to note the first sentence of Note 13 to
             the 2008 Annual Report stated the buyer "will use
             such barges for private use" meaning it would not be
             producing power for sale to third parties in
             competition with Seaboard.  As a result, Seaboard was
             not selling the business, just certain assets of the
             business.  As discussed below, the revenue-producing
             activity of the component will remain the same as
             before the transaction, which is generating
             electricity into the local Dominican Republic power
             grid for sale to third parties.  Most of the
             employees, all of the customer base and operating
             rights have been retained by Seaboard.  Accordingly,
             the sale of these assets did not and will not result
             in the elimination of the power generating component
             or Seaboard operating in or generating cash flows in
             the Dominican Republic.

             In addition, the last sentence of Note 13 in our 2008
             Annual Report stated "Seaboard will retain all other
             physical properties of this business and is
             considering options to continue its power business in
             the Dominican Republic after the sale of these assets
             is completed."  Such assets include the
             administration building, spare parts warehouse, two
             fuel storage tanks and certain line connections to
             the local power grid.  The two assets sold are such
             they would be disconnected and moved to a different
             location leaving the rest of the operations in place.
             In addition, Seaboard has certain power supply
             agreements with various industrial customers for
             which Seaboard would continue to provide power past
             the closing date of the sale.  During the time after
             the sale of the assets, Seaboard intended to buy
             power on the spot market for resale to these
             customers until such time a new generation facility
             began operation.

             In the second quarter Form 10-Q for the period ended
             July 3, 2010, Seaboard announced it was finalizing
             plans to build a 106 megawatt power generating
             facility in the Dominican Republic.   This new power
             barge would replace the assets sold and, when
             delivered later this year, will be placed in the
             exact location where the assets sold use to be.  This
             was also disclosed in the 2010

<PAGE> 4

             Annual Report on Form 10-K in Note 13 by the following
             sentence:  "Seaboard retained all other physical
             properties of this business and is currently building
             a replacement 106 megawatt floating power generating
             facility for use in the Dominican Republic."  This
             business activity, the assets we retained together
             with the new power generating facility makes Seaboard
             a continuing part of the Dominican power supply
             industry.  Nothing was discontinued and no business
             components were sold.

Comment 6:   Reference is also made to your Business - Financial
             Information about Industry Segments and MD&A -
             Overview sections concerning some additional
             information on your Commodity, Trading & Milling
             ("CTM") segment. Within the CTM segment, we note the
             nature of your two types of business activities is
             different as follows:

             (1)  a commodity & trading business where you
                  internationally purchase and trade a number of
                  commodities (wheat, corn soybean meal, rice); and

             (2)  the operation of a grain milling processing
                  business where you mill and produce flour, feed and
                  maize.

             We note that your CTM segment is the largest of your
             six reportable segments relative to your consolidated
             sales, as it represented approximately $1.8 billion
             (or 41%) of the $4.3 billion consolidated sales in
             fiscal 2010. Although the milling operations produce
             products that are supplied by your trading business,
             the nature of these two business (trading and
             milling) activities appear dissimilar with their
             economic characteristics, risks, customers,
             production processes and/or marketing methods. In
             this regard, we have also noted below several
             examples of disclosure in your Form 10-K and Annual
             Report that appear to highlight differences in these
             respective business activities. In MD&A - Overview
             for the Commodity Trading and Milling Segment (page
             11, Annual Report), you discuss that fluctuating
             market conditions for wheat and flour can have a
             significant impact on both the trading and milling
             business sales and operating income. It appears that
             wheat and flour separately impact your trading and
             milling business, respectively. Furthermore, in Item
             1A - Section (c)(4) - Risk Factor for Commodity
             Trading & Milling (page 12, Form 10-K), you disclose
             that you enter into material amounts of significantly
             different derivative products to manage certain
             market risks within the commodity trading portion of
             the business, thus it appears the risks of these two
             businesses are dissimilar. We also note that the mark-
             to-market adjustments for the derivative instruments
             has materially impacted the operating results of the
             CTM segment, as presented in MD&A for this segment's
             operating results (see page 17, Annual Report).  In
             addition, the 2010 Letter to Stockholders (page 3,
             Annual Report) highlights positive results obtained
             from grain trading in Latin America, while also
             stating that grain processing margins were mixed in
             both Africa and the Americas along with a fiscal 2011
             expectation of heavy price

<PAGE> 5

             resistance and generally lower margins and volumes on
             the milling side. As such, it appears you may not meet
             all the criteria as specified in ASC Topic 280-10-50-11
             to aggregate these two operating businesses.

             Please re-evaluate your segment reporting of CTM to
             consider further disaggregation of these two
             operating businesses into separate reportable
             business segments. In the event management still
             continues to believe aggregation of the trading and
             milling businesses as one reportable segment is
             appropriate under the above accounting guidance,
             please provide a clear and complete response that
             provides all the information as specified below:

             (1)  an organizational flowchart of the CTM segment
                  detailing all of its operating segments;

             (2)  the chief operating decision maker(s) ("CODM")
                  of the CTM segment and how executive management of
                  this segment is structured and resources are
                  allocated to the operating segments that comprise the
                  CTM segment;

             (3)  a detailed discussion of each factor in ASC
                  Topic 280-10-50-11 that enables management to support
                  its conclusion that aggregation of all operating
                  segments into the one reportable CTM segment is
                  appropriate;

             (4)  discrete separate financial information for the
                  trading and milling businesses for each of the last
                  three (2008-2010) fiscal years and subsequent 2011
                  interim periods detailing revenues, operating income
                  and geographic sales information, respectively.
                  Please also let us know how much of the sales
                  (quantified) for each of these businesses went to
                  similar customers; and

             (5)  a representative sample copy of the discrete
                  financial information that is regularly furnished (on
                  a quarterly or annual basis) to the CODM for the CTM
                  segment.

             After your additional consideration and re-evaluation
             of this matter, please either revise your financial
             reporting or advise as applicable. We may have
             further comment if management continues to believe
             that the current reporting of CTM as one reportable
             segment is appropriate.

Response:    As disclosed in Note 13 to the Consolidated Financial
             Statements, Seaboard's reporting segments are based
             on information used by Seaboard's Chief Executive
             Officer, Mr. Steve Bresky, in his capacity as CODM,
             to determine allocation of resources and assess
             performance.  Mr. Bresky communicates directly and
             individually with each of the five Chief Executive
             Officers of principal Seaboard operations.  These
             include Rodney Brenneman, Pork,

<PAGE> 6

             Edward Gonzalez, Marine, Hugo Rossi, Sugar,
             Armando Rodriguez, Power and David Dannov, CT&M. Such
             communications include meetings where allocation of
             capital resources, results of operations, and future
             plans are discussed.

             The CT&M segment is an integrated grain trading,
             grain processing and logistics company with primary
             focus on the African and South American markets.  The
             objective of this segment is to create value through
             the world-wide origination, delivery and processing
             of grain by our subsidiaries and affiliates.  Also
             this segment creates value for third-party processors
             by utilizing our grain merchandising strategies and
             logistics knowledge with focus on least cost
             origination.  The CT&M segment is comprised of
             approximately many different components, some
             consolidated and some accounted for on the equity
             method.  These represent either trading functions,
             milling and other locations, or segment overhead and
             administrative functions.   Each of these components
             is part of one business and thus one operating
             segment. In our management reporting we combine
             milling and trading results and evaluate these
             results on a combined basis. This results in key
             management decisions and resource allocation
             decisions made on a combined basis.

             In Seaboard's view, one of the main criteria of a
             operating segment described in ASC Topic 280-10-50-1
             is its operating results are regularly reviewed by
             the chief operating decision (CODM) maker to make
             decisions about resources to be allocated to the
             segment and assess it performance.   In your request
             for information, you ask for a detail discussion of
             ASC Topic 280-10-50-11.  However, that reference is
             to the aggregation criteria for combining two
             separate operating segments.  As noted above,
             Seaboard does not manage CT&M as two separate
             operating segments but rather one business and one
             operating segment comprised of numerous components
             and thus the aggregation criteria does not apply in
             our circumstance.  We do not report trading and
             milling separately because we do not manage CT&M in
             this manner internally.  The critical information
             used by our senior management team responsible for
             overseeing this segment is presented on a combined
             basis.  This information assigns trades to milling
             locations on a non-GAAP basis and reports margin by
             milling channel and margin by third party trades.
             Our segment manager reports directly to our Chief
             Operating Decision Maker (CODM).  Information
             presented to both our CODM and our Board is at a
             combined level consistent with our existing segment
             reporting.  If we were to disaggregate this segment
             into two pieces this would be inconsistent with how
             our CODM and segment management team view the
             business, manage activity, report results and
             allocate resources.

             As noted above, the Chief Executive Officer of the
             CT&M segment is Mr. Dave Dannov.  Mr. Dannov reports
             directly to Mr. Bresky.  Various individuals report
             to Mr. Dannov for both trading and milling
             operations.   However, no

<PAGE> 7

             one individual manages either the entire commodity
             trading operations or the entire milling operations.
             Also reporting to Mr. Dannov is a group of
             approximately twenty individuals that provide
             administrative support functions for both trading
             and milling operations including Accounting, Human
             Resources, Information Systems, Engineering,
             Purchasing, Business Development and other
             Administrative support functions.  There is no
             distinction made in an attempt to split overhead
             between the various businesses that make up CT&M but
             rather these costs are reported internally as one
             category.  Strategy development is done on an
             integrated basis including input from the
             administrative, trading and milling management
             regarding business development opportunities, capital
             expenditures, investments and staff expansion.
             Various meetings are held with both trading and
             milling personnel attending.  Trading and milling
             activities are highly coordinated with daily
             interaction between groups regarding key business
             decisions, including raw material input planning,
             logistics, pricing, product quality, financing and
             many other day-to-day business decisions.

             Each of the trading and milling businesses are
             treated as one collective group for key internal
             reports that are primarily used and relied upon by
             our CODM.  We do not believe it would be appropriate
             or useful to separately prepare financial information
             for external reporting that is inconsistent with how
             we view and manage this business.  The various
             comments in our Form 10-K and Annual Report,
             including the President's letter, are comments made
             to describe and explain various aspects of this
             operating segment to help a reader understand the
             business.

             Organizationally, Mr. Dannov has established
             operating entities or groups of entities in which he
             has placed senior managing executives who report
             directly to Mr. Dannov.  These entities or groups of
             entities are comprised of trading and milling
             entities, which have a common purpose of purchasing
             bulk commodities from anywhere in the world, shipping
             those commodities to milling concerns, processing the
             commodities, and sales of the commodities or refined
             products to wholesalers, manufacturers, distributors,
             bakers or retail entities.  The entities represent an
             integrated group, dependent upon other entities
             within the CT&M segment.    In addition to sourcing
             commodities for the milling businesses, the trading
             office may also supply price management function on
             their behalf.  The results of the milling operations
             are materially impacted by the support provided by
             the trading operations.  The trading operations are
             involved in the procurement and delivery of raw
             materials for the milling operations.  The mills give
             the trading operations direction of quality, quantity
             and timing of delivery.  Conversely in certain sales
             channels the trading entity would not operate without
             milling entities, as they provide the base cargo, or
             only cargo for certain geographic areas.  This
             dependency requires the decision making, the
             management of the group of businesses, the
             organization and reporting to be considered one
             single activity. This is our lens

<PAGE> 8

             and is how our CODM and segment management team manage
             this business.

             The CT&M segment is a combination of operations that
             forms one integrated operation.  When considering all
             of the components of these operations, there are some
             differences but reporting separately is not how the
             business is managed or viewed by Seaboard's executive
             management group, especially Mr. Bresky or Mr.
             Dannov.  Mr. Dannov constantly gives guidance to all
             of CT&M's management to view the operations as one
             integrated business rather than separate component
             parts thus demanding management focus on what is best
             for CT&M as a whole rather than any one specific
             entity.  This is validated by the fact the group
             incentive compensation program shares performance of
             the entire division amongst the different management
             groups.  Additionally, this holistic structure that
             integrates these commodity trading and milling
             activities is also how Mr. Bresky and Mr. Dannov
             communicate the business model to outside parties
             such as bankers, customers, suppliers and potential
             business partners. This structure has historically
             served our organization well and in our view is the
             most appropriate way to view and evaluate this
             portion of our business by an investor.

             Additional information requested such as organization
             chart, discrete separate financial information, and
             representative sample copies of the discrete
             information that is regularly furnished to the CODM
             for the CT&M segment will be provided on a
             confidential basis in a separate letter since such
             information is not public information.


Schedule II - Valuation and Qualifying Accounts

Comment 7:   Please revise future filings to expand the schedule
             to include the applicable financial information on
             the valuation allowance for deferred tax assets and
             the valuation account for LIFO inventory adjustments.

Response:    In future filings, we will expand the schedule as
             requested.

Signatures, page 23

Comment 8:   In future filings, please revise the second half of
             the signature page to have your principal executive
             officer, principal financial officer and principal
             accounting officer sign in their individual
             capacities. Refer to General Instruction D to Form 10-
             K.

Response:    In future filings, we will revise the signature page
             as requested.


<PAGE> 9


Definitive Proxy Statement on Schedule 14A

2010 Executive Compensation Components, page 19

Comment 9:   We note you paid your named executive officers cash
             bonuses in amounts above the mandatory bonus amounts
             set forth in the employment agreements. We also note
             that although the company does not have specific
             targets, the 2010 bonuses of your named executive
             officers were "reflective of the operating results"
             of the company. In future filings, please revise to
             disclose the process the board undertook to determine
             the amount of bonuses awarded to the named executive
             officers and the specific factors, including a
             general overview of individual performance and
             business unit goals, the board considered.
             Specifically disclose the operating results that the
             board considered in granting bonuses and how the
             board used these results to determine the exact
             amount of the bonus award received by each named
             executive officer.

Response:    We state in our Proxy Statement on page 20 that "the
             Board of Directors establishes compensation based
             upon a subjective review of Company performance and
             individual performance."  We further explain that the
             Board subjectively evaluates both performance and
             compensation.   The Board does not utilize any
             metrics or any other specific factors, and there
             aren't individual or business unit goals which are
             considered, in establishing compensation.  Rather,
             the Board subjectively establishes compensation in
             light of existing compensation and a subjective
             assessment of how Seaboard is doing.  In the future,
             if there are specific factors which are considered,
             and if there are individual performance or business
             unit goals, these will be disclosed.   We will also
             clarify that the process utilized by the Board of
             Directors in establishing compensation is subjective.

Comment 10:  We note that the board evaluates compensation so that
             the amounts paid to your key employees remains
             "competitive relative to compensation paid to
             similarly situated executives of [y]our peer
             companies" and that you determine bonuses based on a
             "subjective evaluation of the market data." As such,
             it appears that you may benchmark compensation.
             Please revise in future filings to provide the
             companies against which you benchmark or provide an
             analysis as to why this is not necessary. Please also
             revise future filings to clarify how you conducted a
             subjective evaluation of "market data" and the data
             to which you are referring.

Response:    The Board sometimes, but not always, will consider
             the average compensation paid to executives of other
             companies, which may be in a business related to a
             business of Seaboard, or of a similar size, or
             otherwise have some other similarity to Seaboard.
             When they do so, a general review of this data is
             undertaken, but no specific benchmark is utilized.
             In the future, if the executive compensation of peer
             companies is reviewed by the Board in determining
             compensation, we will set forth the peer companies,
             and if the evaluation of this

<PAGE> 10

             data is conducted by any process other than a
             subjective review of the data, we will describe the
             process.

Form 10-Q for the quarter ended April 2, 2011

Note 9. Segment Information, page 13

Comment 11:  We note your disclosure that on April 20, 2011 you
             signed a short-term lease agreement that allowed you
             to resume operations of one of the barges (EDM) sold
             in the Dominican Republic on April 8, 2011. In light
             of your disclosure that you will recognize the entire
             $51.4 million gain on the sale of the barges in
             operating income in the second quarter of 2011,
             please explain to us why you believe it is
             appropriate to record the gain related to the sale of
             the EDM barge at the time of sale when you have
             entered into a sale-leaseback transaction. Your
             response should specifically address your
             consideration on recognizing the gain over the
             leaseback period that extends through approximately
             March 31, 2012. Please refer to the guidance in ASC
             840-40-25-3.

Response:    ASC 840-40-55-82 provides an example, similar to
             Seaboard's transaction, whereby the seller negotiates
             a leaseback of a factory for one year because its new
             facilities are under construction and approximately
             one year will be required to complete the new
             facilities.  In this example, since the leaseback was
             deemed a minor leaseback, the seller-lessee
             recognized the sale and the full gain at the time of
             sale.

             In Seaboard's transaction, the leaseback is deemed a
             minor leaseback because the present value of the
             leaseback is significantly less than 10 percent of
             the fair value of the EDM barge sold. It should also
             be noted that Seaboard was approached by the buyer to
             lease the property in late March 2011, well after the
             effective date of the sale agreement of March 2, 2009
             and that the lease period was slightly less than one
             year.  The expected life of this asset is
             considerably longer than this short lease term.  The
             amount of rentals called for by the lease was deemed
             reasonable.  As a result, the condition in ASC 840-40-
             25-3 was met so Seaboard accounted for the sale and
             subsequent minor leaseback as separate transactions
             based on their respective terms.  Accordingly,
             Seaboard recognized the full $51.4 million gain on
             the sale of barges in operating income in the second
             quarter of 2011 (at the time of sale) in accordance
             with ASC 840-40-25-3.


In summary, we have carefully considered the comments and views
expressed in your letter and believe your comments will improve
our future financial reporting.   We believe our responses fully
respond to the comments provided, and we do not believe that
these inquiries or responses indicate the existence of any
deficiencies in financial reporting controls or procedures.  If
you have any questions or require any further information, please
call John Virgo at (913) 676-8800.

<PAGE> 11


Very truly yours,

SEABOARD CORPORATION


/s/Robert L. Steer
Robert L. Steer
Executive Vice President and Chief
Financial Officer

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