February 11, 2015 - SEC.gov

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tories- is not otherwise significantlyrelated to the Company's business." In Hewlett-Packard Company, the proposal requestedthat the company relocate or close its offices in Israel, divest itself of land owned in Israel,and write letters to Israeli officials explaining why the company could not maintain itspresence. Once again, in permitting exclusion ofthe proposal, the Staff noted that thecompany satisfied the economic tests under Rule 14a-8(i)(5) and found that the proposal wasnot "otherwise significantly related to the Company's business."As was the case in the situations referenced in the preceding paragraph, the Proposaldoes not evidence a significant connection between Corning's de minimis operations in Israeland Corning's business as a whole. Instead, the Proposal addresses the general political goalof the Proponent. Additionally, since Corning began operations in Israel two years ago, it hasnever directly (or to its knowledge, indirectly) supported or permitted any discriminatory orunjust practices - in employment or otherwise. As discussed in more detail below, Corninghas global non-discrimination and equal employment opportunity policies in place. Becausethere is no evidence that Corning's operations have contributed to or supported any of thepurported injustice or inequality the Proponent seeks

Linda E. Jolly . Corning Incorporated . jollyle@corning.com . Re: Corning Incorporated . Incoming letter dated December 9, 2014 . Dear Ms. Jolly: This is in response to your letter dated December 9, 2014 concerning the shareholder proposal submitted to Corning

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