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U.S. Securities and Exchange Commission

October 21, 2005

Response of the Office of Chief Counsel
Division of Corporation Finance


Unocal Corporation
Incoming letter dated October 21, 2005

Based on the facts presented, the Division will not object if Unocal Corporation stops filing periodic reports under the Securities Exchange Act of 1934. In reaching this position, we note that Unocal has already filed post-effective amendments removing from registration unsold securities under all effective registration statements on Form S-3 and Form S-8, and that Unocal has already filed a notice on Form 15 making appropriate claims under rule 12h-3 under the Exchange Act.

Our position is based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach a different conclusion. Further, this response expresses the Division's position on enforcement action only and does not express any legal conclusion on the questions presented.


/s/ Robyn Manos
Robyn Manos
Special Counsel

Incoming Letter:

The Incoming Letter is in Acrobat format.


Modified: 10/24/2005