July 3, 2018

Giovanni Caforio
Chairman of the Board and Chief Executive Officer
Bristol-Myers Squibb Company
345 Park Avenue
New York, NY 10154

       Re: Bristol-Myers Squibb Company
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 13, 2018
           Form10-Q for the Quarterly Period Ended March 31, 2018
           Filed April 26, 2018
           File No. 001-01136

Dear Mr. Caforio:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form10-Q for the Quarterly Period Ended March 31, 2018

Note 3. Revenue Recognition, page 8

1.    Your arrangements may include fixed up-front amounts as well as variable
consideration
      such as contingent development and regulatory milestones, sales-based
milestones and
      royalties. Please tell us, and propose accounting policy disclosure for
future filings that
      clarifies, the following:
        what method you are using to estimate your variable consideration under
ASC 606-10-
          32-8, and why it is appropriate to apply that method, and
        how you allocate and recognize variable consideration.
 Giovanni Caforio
Bristol-Myers Squibb Company
July 3, 2018
Page 2
2.       You disclose on page 9 that your alliance and other arrangements may
include the transfer
         of certain rights to develop or commercialize investigational
compounds or products and
         joint obligations to provide development, distribution, promotion,
sales and marketing
         services and clinical or commercial product supply. Please tell us,
and propose accounting
         policy disclosure for future filings that clarifies, the facts and
circumstances that result in
         your use of the accounting in ASC 606-10-55-65 for sales-based
milestones and sales-
         based royalties for your performance obligations, including when a
single performance
         obligation includes a license (or licenses) of intellectual property
and one or more of the
         other goods or services noted above. Please identify for us any
alliances to which you
         apply the accounting in ASC 606-10-55-65 that involve a license and
development
         activities before regulatory marketing approval. In addition, provide
an analysis
         supporting that the license of intellectual property is the
predominant item to which the
         sales-based milestones and sales-based royalties relate.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Keira Nakada at 202-551-3659 or Bonnie Baynes at
202-551-4924 with
any questions.

FirstName LastNameGiovanni Caforio
Comapany NameBristol-Myers Squibb Company
                                                                 Division of
Corporation Finance
July 3, 2018 Page 2                                              Office of
Healthcare & Insurance
FirstName LastName