The Company does not currently sell any products directly or indirectly into any of the referenced countries. Longstanding Company policy, as set forth in its Code of Conduct and Business Practices Guidelines, is that any such sales be conducted in compliance with applicable U.S. laws and regulations relating to economic sanctions and export controls. In the past, certain foreign subsidiaries of the Company sold limited quantities of various oral care, personal care and household care products to unrelated third party distributors or wholesalers selling into Iran, Sudan and Syria, but not Cuba or North Korea. (See response to item 2 below for the approximate amounts of such sales.) The products sold to these third parties were made in factories owned by foreign subsidiaries of the Company and located outside of the United States.

Such sales did not involve any agreements, commercial arrangements or other contacts with the governments of the above countries or entities controlled by such governments, other than providing ordinary course customs and product health documentation as required by local law.

As of the end of 2007, sales to the above countries had ceased, and the Company does not intend to make further sales either directly or indirectly through distributors into these countries. As noted above, sales have not been made nor will be made to Cuba or North Korea.

For clarity, we point out that, it is possible that, without the Company’s knowledge or consent, third party customers of the Company or its subsidiaries in various locations around the world have in the past or may in the future engage in diversion or, in other words, sell into sanctioned or embargoed countries products purchased from the Company or its subsidiaries for sale in other countries. Such unauthorized diversion might account for the May 2007 news report cited by you of product availability in Cuba. It is the Company’s policy to make all efforts to stop diversion to embargoed or sanctioned countries whenever the Company becomes aware of it.

Please discuss the materiality of any contacts described in response to the foregoing comment, and whether they would constitute a material investment risk for your security holders. You should address materiality in quantitative terms, including the approximate dollar amounts of any associated revenues, assets and liabilities for the last three years concerning each referenced country. Also address materiality in terms of qualitative factors that a reasonable investor would deem important in making an investment decision, including the potential impact of corporate activities upon a company’s reputation and share value.

The Company believes that the contacts described above are immaterial and do not constitute a material investment risk for our security holders from either a quantitative or a qualitative point of view.