Mail Stop 3030

                                                                 July 5, 2018

     Via E-mail
     Jamie S. Miller
     Senior Vice President and Chief Financial Officer
     General Electric Company
     41 Farnsworth Street
     Boston, Massachusetts 02210

            Re:    General Electric Company
                   Form 10-K for the Fiscal Year Ended December 31, 2017
                   Filed February 23, 2018
                   Form 10-Q for the Quarterly Period Ended March 31, 2018
                   Filed May 1, 2018
                   File No. 001-00035

     Dear Ms. Miller:

            We have reviewed your filing 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.

     Form 10-K for the Fiscal Year Ended December 31, 2017

     General

     1.     In a letter to the staff dated July 30, 2015, you discussed limited
contacts with Sudan and
            Syria. As you know, Sudan and Syria are designated by the State
Department as state
            sponsors of terrorism and are subject to U.S. economic sanctions
and/or export controls.
            Please describe to us the nature and extent of any past, current
and anticipated contacts
            with Sudan and Syria since your 2015 letter, including contacts
with their governments,
            whether through subsidiaries, affiliates, joint ventures or other
direct or indirect
            arrangements. Please also discuss the materiality of those
contacts, in quantitative terms
            and in terms of qualitative factors that a reasonable investor
would deem important in
            making an investment decision. Tell us the approximate dollar
amounts of revenues,
 Jamie S. Miller
General Electric Company
July 5, 2018
Page 2

       assets and liabilities associated with Sudan and Syria for the last
three fiscal years and the
       subsequent interim period. Address for us the potential impact of the
investor sentiment
       evidenced by divestment and similar initiatives that have been directed
toward companies
       that have operations associated with U.S.-designated state sponsors of
terrorism.

Management's Discussion and Analysis of Financial Condition and Results of
Operations

Key Performance Indicators, page 18

2.     When presenting firm backlog in future filings, separately disclose the
portion thereof not
       expected to be filled within the current year. Refer to Item
101(c)(1)(viii) of
       Regulation S-K.

Power   Commentary: 2017-2016 and 2016-2015, page 31

3.     In future filings, disclose any material known trends driving the
variability in AGP
       upgrades.

Aviation   Commentary: 2017-2016 and 2016-2015, page 43

4.     We note your disclosure regarding continued growth in air travel for the
periods
       presented. In future filings, disclose any material known trends that
have caused the
       declining equipment revenues for the years presented.

GE Corporate Items and Eliminations, page 58

5.     In future filings revise to clarify the difference between the
restructuring and other
       charges included in the tables on pages 58 and 96 and the amounts
included on page 60.

Liquidity Sources, page 72

6.     We note your disclosure that GE cash and equivalents includes $7.0
billion at BHGE.
       Indicate in future filings how you would access that cash. Disclose any
restrictions and
       how any such restrictions or payment of a pro rata dividend would impact
your cash and
       liquidity.

7.     We note the disclosure in the last sentence of the first paragraph of
this section. Given
       your disclosure that GE Capital does not expect to make a common share
dividend
       distribution to GE for the foreseeable future, disclose the
circumstances under which
       GE Capital has the right to compel GE to borrow under the disclosed
credit lines and
       transfer the proceeds as loans to GE Capital. If GE Capital could
require you to increase
       your indebtedness without increasing its cash flows to you, please
include appropriate
       risk factor disclosure.
 Jamie S. Miller
General Electric Company
July 5, 2018
Page 3

8.     In your future filings that contain your cash and equivalents table,
please add a number
       that shows the cash and cash equivalents available to GE without
accessing the cash at
       BHGE and without the cash that may be restricted as indicated in
footnote (a) to your
       current table.

Cash Flows, page 79

9.     We note from the final transcript of the Insurance Update Call from
January 16, 2018 the
       statements that "previously, the GE Capital preferred stock carried
back-to-back terms
       with the GE parent" and that you are "modifying the GE Capital internal
preferred stock
       to be mandatorily convertible to effectively strengthen GE Capital's
common equity." If
       this conversion is a known trend, revise your future filings to indicate
the impact and
       status of this conversion. For example, if this means that after such
conversion, GE
       Capital would no longer pay preferred stock dividends to GE and that GE
would have to
       rely on its own cash flows to pay dividends on the preferred shares held
by outside
       investors, please make that clarification.

Supplemental Information

GE Industrial Structural Costs and GE Industrial Structural Costs, Excluding
Acquisitions and
Dispositions (Non-GAAP), page 96

10.    We reference your non-GAAP measure of Industrial structural costs.
Please explain to us
       the purpose of this measure, what it is intended to represent and why
you believe it is
       useful to investors. Explain how you determined the significant
adjustment for segment
       variable costs and the reason that the adjustment for corporate
restructuring and other
       charges does not agree to the amount reported on page 60.

GE Industrial Operating + Verticals Earnings and EPS (Non-GAAP), page 98

11.    Please tell us how you determined the adjustment of $(557) for GE
capital other
       continuing earnings (loss) (Other Capital) for the measure of verticals
earnings.

GE Industrial Return on Total Capital (GE Industrial ROTC) (Non-GAAP), page 101

12.    Please explain to us how you determined the average debt amounts for
purposes of your
       non-GAAP measure of adjusted GE Industrial capital.

Risk Factors

Funding & liquidity, page 109

13.    We note your recent statement that your dividend will be a function of
free cash flows
       and cash from dispositions. Expand your risk factor disclosure in future
filings to address
 Jamie S. Miller
General Electric Company
July 5, 2018
Page 4

       material risks to your dividend from your funding and liquidity,
including, as appropriate,
       from any changes to your credit ratings or other factors that may impact
borrowing terms.


Form 10-Q for the Quarterly Period Ended March 31, 2018

Management's Discussion & Analysis of Financial Condition and Results of
Operations

Other Terms Used By GE, page 5

14.    We note that your discussion of backlog includes firm purchase orders
that have not yet
       been received. Please explain to us why orders not yet received would be
considered
       firm purchase orders. Refer to the guidance in Item 101(c)(viii) of
Regulation S-K.

Consolidated Results, page 8

15.    We reference your non-GAAP measure of organic industrial segment
revenues excluding
       Power and Oil & Gas segments. In future filings, please provide the
reconciliation
       required by Item 10(e) of Regulation S-K.

Supplemental Information, page 43

16.    In the tables on pages 45 and 46 you present the measures entitled
Operating earnings
       (GAAP), Operating EPS (GAAP), GE Industrial operating earnings (GAAP),
and
       GE Industrial operating EPS (GAAP) which appear to be non-GAAP measures
as they
       exclude amounts that are included in the most directly comparable GAAP
measure.
       Please revise your presentation in future filings to correctly label the
measures as
       non-GAAP and to provide all disclosures required by Item 10(e) of
Regulation S-K.

17.    Further, we note that Item 10(e)(1)(ii)(E) of Regulation S-K prohibits
you from using
       titles for non-GAAP measures that are the same as, or confusingly
similar to, titles or
       descriptions used for GAAP financial measures. Tell us how your use of
the titles
       Operating earnings and Operating EPS, which are accepted U.S. GAAP
terms, complies
       with that guidance, or revise your presentation in future periods to
comply.

18.    Please tell us how you determined each of the adjustments for GE
Industrial U.S. tax
       reform enactment in the table on page 45.
 Jamie S. Miller
General Electric Company
July 5, 2018
Page 5

Financial Statements

Note 1. Basis of Presentation and Summary of Significant Accounting Policies

Accounting Changes, page 62

19.    We note your discussion of the impact of the new revenue accounting
guidance on your
       (i) long-term service agreements, (ii) aviation commercial engines, and
(iii) all other large
       equipment. In the long-term service contracts discussion on page 63 you
appear to
       attribute the entire $8.3 billion reduction in your contract assets to
the change in
       accounting for these agreements, but in the following section you
attribute $1.8 billion of
       the reduction in contract assets to the change in accounting for
aviation commercial
       engines. Further, in your Form 8-K filed April 13, 2018, referenced in
this note, you
       disclose a $1.0 billion reduction in 2017 Renewable Energy segment
revenues, a business
       you indicate was most significantly impacted by the change in accounting
for all other
       large equipment. To help us better understand your accounting change,
please quantify
       for us the change in your 2017 and 2016 revenues, the change in your
beginning retained
       earnings at January 1, 2016 and the change in contract assets at
December 31, 2017
       resulting from the ASC 606 required changes in accounting for each of
your (i) long-term
       service agreements, (ii) aviation commercial engines, and (iii) all
other large equipment.

20.    In future filings, please disclose the underlying reason for the
accelerated timing of
       revenue recognition for All Other Large Equipment and explain how the
timing of
       transfer of control differs from the transfer of risks and rewards.
Explain to us, in
       quantified detail, the impact of this change on your financial
statements.

Note 9. Revenues, page 74

21.    For performance obligations satisfied over time, please explain to us
how you considered
       the requirements of ASC 606-10-50-17 and 50-20 related to disclosing the
significant
       judgments, methods, inputs and assumptions used in determining
transaction prices,
       estimating variable consideration, and allocations to performance
obligations.

22.    As a related matter we note from your disclosure on page 40 that you
limit the amount of
       variable consideration used to estimate transaction price such that it
is improbable that a
       significant revenue reversal will occur in future periods. Explain to us
the types of
       variable consideration to which the constraint is applied and how the
uncertainty about
       the amount of consideration is resolved. Also explain to us how you
considered the
       guidance in ASC 606-10-50-12b and 606-10-50-15 related to disclosure of
variable
       consideration.

23.    We note your disclosure that you receive progress payments from
customers for large
       equipment purchases, which is generally to reserve production slots.
Please tell us how
 Jamie S. Miller
General Electric Company
July 5, 2018
Page 6

       you considered ASC 606-10-32-15 in determining whether a significant
financing
       component exists.

Note 19. Commitments, Guarantees, Product Warranties and Other Loss
Contingencies

Other Loss Contingencies, page 93

24.    We note that you recorded a reserve of $1.5 billion during the first
quarter of 2018 in
       connection with the DOJ's ongoing investigation regarding potential
violations of
       FIRREA by WMC and GE Capital. In future filings, disclose the specific
underlying
       events and circumstances that resulted in this reserve. In addition, we
note your
       discussion of the possibility that WMC will file for bankruptcy in the
event of an adverse
       finding in the TMI case. Please revise future filings to address how
this could impact
       your WMC reserve.

        You may contact Julie Sherman at (202) 551-3640, or Brian Cascio,
Accounting Branch
Chief, at (202) 551-3676 if you have questions regarding comments on the
financial statements
and related matters. Please contact Tim Buchmiller at (202) 551-3635 or me at
(202) 551-3528
with any other questions.


                                                           Sincerely,

                                                           /s/ Amanda Ravitz

                                                           Amanda Ravitz
                                                           Assistant Director
                                                           Office of
Electronics and Machinery


cc:    Christoph A. Pereira, Esq.
       Vice President, Chief Corporate, Securities & Finance Counsel