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November 21, 2006


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



Please find below the Company's response to the Staff's
letter to me dated October 24, 2006.  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.

Please direct any future correspondence on this topic to
Frank Sklarsky, my successor as Chief Financial Officer of
Eastman Kodak Company.







                              Sincerely,

                              /s/ Robert H. Brust






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

General

1.   We have reviewed your October 6, 2006, response, in
which you discuss your compliance with U.S. export law.
Please clarify for us whether any of your foreign
subsidiaries or branches has provided or provides products,
technology or services into Iran, Sudan or Syria that (i)
could not lawfully be provided by a U.S. company or, (ii) if
provided into those countries by a U.S. company or if
comprised of U.S.-origin components, would require a license
from the Treasury Department's Office of Foreign Assets
Control or the Commerce Department's Bureau of Industry and
Security.  If any of your foreign subsidiaries or branches
has provided or provides such products, technology or
services into any of those countries, please advise us
whether, to the best of your knowledge, understanding, and
belief, any of the products, technology or services have
military application(s), and describe the possible military
uses.


The Company does not supply any products, technology or
services into Iran, Sudan or Syria from any U.S. company.
Prior to the effective date of the Executive Order banning
sales of U.S. products to Syria, a U.S. branch of the Company
based in Dubai, UAE sold limited quantities of Kodak products
to customers in Syria.  There have been no sales by this
branch into Syria since the embargo went into effect.  All
sales into the countries indicated above are made from
foreign subsidiaries and to the best of the Company's
knowledge, understanding and belief do not contain U.S.-
origin content, the U.S.-origin content was de minimis, were
made from normal, stocked inventory, or the appropriate
licenses were obtained.  Therefore, the sales are in full
compliance with U.S. Export Law.

In response to the Staff's comment, sales of these products
and services would require a license from the Treasury
Department's Office of Foreign Assets Control ("OFAC") or
from the Commerce Department's Bureau of Industry and
Security ("BIS") if the sales had been made from a U.S.
company.  However, to the best of the Company's knowledge,
understanding and belief, any sales of products or services
by a foreign subsidiary into Iran, Syria or the Sudan were
either conducted in a manner that would not require a license
or were pursuant to a license obtained from OFAC or BIS.

In addition, to the best of the Company's knowledge,
understanding and belief, none of the products, technology or
services that are provided into these countries were designed
or intended for military applications.