PFIZER INC.
235 East 42nd Street
New York, New York 10017
September 23, 2015
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Mellissa Campbell Duru
| Re: | Pfizer Inc. |
| Registration Statement filed on Form S-4 |
| File No. 333-206758 |
| Filed September 3, 2015 |
Ladies and Gentlemen,
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Pfizer Inc. (the “Registrant”) hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 3:00 p.m. EST on Friday, September 25, 2015, or as soon thereafter as practicable.
Please note that the Registrant acknowledges the following:
| • | should the Securities and Exchange Commission (“the Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please contact Stacy J. Kanter, Skadden, Arps, Slate, Meagher & Flom LLP at (212) 735-3497 with any questions you may have concerning this request. In addition, please notify Ms. Kanter when this request for acceleration has been granted.
Very truly yours,
/s/ Margaret M. Madden
Margaret M. Madden
Vice President and Corporate Secretary,
Chief Counsel – Corporate Governance
| cc: | Skadden, Arps, Slate, Meagher & Flom LLP |