United States securities and exchange commission logo October 8, 2020 Laura J. Schumacher, Esq. Vice Chairman, External Affairs and Chief Legal Officer AbbVie Inc. 1 North Waukegan Road North Chicago, Illinois 60064 Re: AbbVie Inc. Registration Statement on Form S-4 Filed October 2, 2020 File No. 333-249277 Dear Ms. Schumacher: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Alan Campbell at 202-551-4224 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Sophia Hudson, P.C.