Company Name:  Ford Motor Company
Public Availability Date: January 2, 2008

Document Sections:

INQUIRY LETTER
STAFF REPLY LETTER

[INQUIRY LETTER]

Securities and Exchange Commission
Division of Corporation Finance
Office of the Chief Counsel
100 F Street, N.E.
Washington, D.C. 20549

Re: Omission of Shareholder Proposal Submitted by Ms. Jane Van Driessche

Ladies and Gentlemen:

Pursuant to Rule 14a-8(j) promulgated under the Securities Exchange Act of 1934, as amended (the "Act"), Ford Motor Company ("Ford" or the "Company") respectfully requests the concurrence of the staff of the Division of Corporation Finance (the "Staff") of the Securities and Exchange Commission (the "Commission") that it will not recommend any enforcement action to the Commission if the shareholder proposal described below is omitted from Ford's proxy statement and form of proxy for the Company's 2008 Annual Meeting of Shareholders (the "Proxy Materials"). The Company's Annual Meeting of Shareholders is scheduled for May 8, 2008.

Ms. Jane Van Driessche (the "Proponent") has submitted for inclusion in the 2008 Proxy Materials a proposal that would require the Company to hold annual meetings in the Dearborn, Michigan area (see Exhibit 1; the "Proposal"). The Company proposes to omit the Proposal from its 2008 Proxy Materials for the following reason:

The Proposal is excludable under Rule 14a-8(i)(7) because it deals with matters relating to the Company's ordinary business operations.

The Proposal Deals with Matters Relating to the Company's Ordinary Business Operations

Rule 14a-8(i)(7) provides that a shareholder proposal may be excluded from a company's proxy materials "if the proposal deals with a matter relating to the company's ordinary business operations." Ford believes that the location of its annual meeting clearly relates to the ordinary business operations and that it may properly exclude the Proposal from its Proxy Materials under Rule 14a-8(i)(7).

The Staff has consistently allowed exclusion of proposals dealing with setting the date, location, and matters concerning the conduct of shareholder meetings as dealing with ordinary business matters. See The Gillette Company (February 4, 2004) (exclusion allowed where proposal required the site of annual meetings be fixed in Massachusetts); Verizon Communications, Inc., (December 16, 2002) (exclusion allowed where proposal required that annual meetings be held at least every other year in New York City); Verizon Communications, Inc., (February 25, 2002) (exclusion allowed where proposal recommended that the board limit sites of future annual meetings to regions where rate payers live); The Gillette Company (February 22, 2005) (exclusion allowed where proposal requested annual meeting be two to three hours in length and that food be served); and Bank of America Corporation (December 14, 2006) (exclusion allowed where proposal requested that the annual meeting be held on a Friday, Saturday, or Monday). See also, Raytheon Company (January 19, 2006) and Bank of America Corporation (January 10, 2003).

Determining the location of the annual meeting requires an evaluation of many factors, including the feasibility of attendance by management and directors, the management, staff and financial resources necessary to support the meeting at a location, the availability and cost of the facilities, and the accessibility of the location to shareholders. The Company's management has a unique and intimate knowledge of the Company's business, and, thus, can make an informed decision as to the appropriate location for the Company's annual meeting of shareholders. It is impractical for the Company's shareholders to make this decision as they do not, as a group, have the same knowledge of the Company with respect to these factors. Moreover, to fix a specific location for all future annual meetings would limit the discretion of the Board of Directors and management to hold meetings in a place other than that specified in the Proposal. Such an advance determination would eliminate the flexibility needed to fix the location of shareholder meetings based upon particular circumstances in a given year.

The Proposal seeks to establish the location of shareholder meetings. Matters relating to the conduct of shareholder meetings, including the location, have routinely been found to relate to matters of ordinary business, and clearly do not raise any significant policy concerns. Based on the foregoing and consistent with the precedent cited above, the Company respectfully requests the concurrence of the Staff in exclusion of the Proposal pursuant to Rule 14a-8(i)(7).

Conclusion

For the foregoing reasons, it is respectfully submitted that the Proposal may be excluded from Ford's 2008 Proxy Materials. Your confirmation that the Staff will not recommend enforcement action if the Proposal is omitted from the 2008 Proxy Materials is respectfully requested.

In accordance with Rule 14a-8(j), the Proponent is being informed of the Company's intention to omit the Proposal from its 2008 Proxy Materials by sending her a copy of this letter and its exhibit. Seven copies of this letter are enclosed. Please acknowledge receipt by stamping and returning one copy in the enclosed self-addressed stamped envelop.

If you have any questions, require further information, or wish to discuss this matter, please call Jerome Zaremba (313-337-3913) of my office or me (313-323-2130).

Very truly yours,

/s/

Peter J. Sherry, Jr.

Enclosure

Exhibits

cc: Ms. Jane Van Driessche (via Federal Express)

[STAFF REPLY LETTER]

January 2, 2008

Response of the Office of Chief Counsel Division of Corporation Finance

Re: Ford Motor Company Incoming letter dated December 21, 2007

The proposal relates to the location of Ford's annual meetings.

There appears to be some basis for your view that Ford may exclude the proposal under rule 14a-8(i)(7), as relating to Ford's ordinary business operations (i.e., the location of Ford's annual meetings). Accordingly, we will not recommend enforcement action to the Commission if Ford omits the proposal from its proxy materials in reliance on rule 14a-8(i)(7).

Sincerely,

/s/

Greg Belliston
Special Counsel