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<SEC-DOCUMENT>0000031235-07-000030.txt : 20070323
<SEC-HEADER>0000031235-07-000030.hdr.sgml : 20070323
<ACCEPTANCE-DATETIME>20070130143348
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000031235-07-000030
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20070130

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			EASTMAN KODAK CO
		CENTRAL INDEX KEY:			0000031235
		STANDARD INDUSTRIAL CLASSIFICATION:	PHOTOGRAPHIC EQUIPMENT & SUPPLIES [3861]
		IRS NUMBER:				160417150
		STATE OF INCORPORATION:			NJ
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		343 STATE ST
		CITY:			ROCHESTER
		STATE:			NY
		ZIP:			14650
		BUSINESS PHONE:		7167244000

	MAIL ADDRESS:	
		STREET 1:		343 STATE STREET
		CITY:			ROCHESTER
		STATE:			NY
		ZIP:			14650
</SEC-HEADER>
<DOCUMENT>
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<FILENAME>filename1.txt
<TEXT>
<PAGE> 1

January 30, 2007


Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549


Attention:  Angela Crane, Branch Chief


Regarding:  Eastman Kodak Company
            Form 10-K for the fiscal year ended December 31, 2005
            File No. 001-00087


Dear Ms. Crane:

Please find attached the Company's response to the Staff's
letter to me dated January 8, 2007.  If you have any
questions, please call Diane Wilfong (Kodak) at (585) 781-
5650, Laurence Hickey (Kodak) at (585) 724-3378 or Brian Lane
(Gibson, Dunn & Crutcher) at (202) 887-3646.

                              Sincerely,

                              /s/ Frank S. Sklarsky

                              Frank S. Sklarsky
                              Chief Financial Officer and
                              Executive Vice President


Attachment

cc: Brian Lane, Esq.


<PAGE>2

Form 10-K for the fiscal year ended December 31, 2005

General

1.   We refer you to the representation in your response letter
     dated December 15, 2006, that your line of non-destructive
     testing films and developing chemicals has the potential to
     be designated "dual use" by the Commerce Department's Bureau
     of Industry and Security.  Please advise us whether the
     referenced film-developing chemicals, which your foreign
     subsidiaries provide to Iran, Sudan, and/or Syria, can be
     used as agents or precursors for agents in chemical weapons.
     Please also clarify for us into which of these countries the
     film-developing chemicals are provided.

To the best of Eastman Kodak Company's ("Kodak") management's
knowledge, our non-destructive testing film developing chemicals
cannot be used as agents or precursors for agents in chemical
weapons.

Sales of small quantities (less than $5,000 per year) of these
chemicals were made by an overseas subsidiary of Kodak to
civilian customers in Syria in 2005 and 2006.

</TEXT>
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