Exxon Mobil Corporation
Beverley A. Babcock
5959 Las Colinas Boulevard
Assistant Controller
Irving, TX 75039
ExxonMobil
April 7, 2010
Mr. H. Roger Schwall
Assistant Director
U. S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.W., Stop 7010
Washington, DC 20549
Re:
Exxon Mobil Corporation
Form 10-K for the Fiscal Year Ended December 31, 2009
Filed February 26, 2010
File No. 1-02256
Dear Mr. Schwall:
The purpose of this letter is to confirm our understanding, based on my phone conversation with Mark Wojciechowski, that the SEC has taken no exception to our request for an extension to April 30, 2010, to respond to the questions listed in the SECs letter dated April 1, 2010. The primary reasons for our request for additional time are to allow time to gather information and the availability of key management who will be reviewing our responses. In addition, many of the personnel involved in preparing our responses are also actively engaged in preparing and filing first quarter financial statements. We hope to be able to submit our response earlier than April 30.
For the staffs information, we note that the proxy statement for ExxonMobils 2010 annual meeting of shareholders had already gone to press at the time we received the comment letter regarding our 2009 10-K. (Because of our large shareholder base, a lead time of approximately three weeks is required to print and prepare our proxy statement for mailing.) Accordingly, the definitive proxy statement that we expect to file on April 13, 2010, will include substantially the same disclosure as in Part III of the 10-K. To the extent the staffs comments apply to that disclosure, we will consider the comments to apply equally to the definitive proxy statement.
Please do not hesitate to contact me at 972-444-1271 if you have any questions.
Yours truly,
By: /s/ Beverley A. Babcock
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Name:
Beverley A. Babcock
Title: Assistant Controller