CompanyName: Prudential Financial, Inc. (Recon.)
Public Availability Date: January 25, 2008

Document Sections:

INQUIRY LETTER
STAFF REPLY LETTER

[INQUIRY LETTER]

January 12, 2008

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

Re: Prudential Financial - Omission of Shareholder Proposal - 12/27/07

Ladies & Gentlemen:

I am the proponent of the Shareholder proposal submitted on a timely basis to Prudential Financial for the purpose of directing the company to provide the more than 2,000,000 shareholders with the option of a cash dividend or a dividend re-investment plan.

The Company obviously objects and has submitted in papers dated Dec. 27, 2007 by Corporate VP and Secretary Kathleen M. Gibson for your consideration to eliminate my proposal from shareholder consideration at the forthcoming "Annual Meeting".

The Company has resisted my first attempt requesting the formation of a dividend re-investment plan and, since I opted to go the shareholder route, the Company is once again attempting to thwart my efforts to bring this matter for shareholder consideration.

One of the provisions of the act is to protect shareholders' interest and to allow them to submit shareholder proposals for their consideration.

It is important to note that, when corporate officers don't respond appropriately, shareholders have the right to submit shareholder proposals during an appropriate time period so that matters can be considered by the shareholders. I would submit to the Commission that that is the very reason why I submitted my "shareholder proposal" due to the intransigence of the Board of Directors of the Prudential Financial Company.

I have enclosed copies of correspondence from the company concerning my previous requests as well as company issued dividend notices.

In conclusion, I am requesting that the Commission disallow Ms. Gibson's request for exclusions and permit my shareholder proposal to go forward for forthcoming shareholder consideration. While the Board realizes "boulder" size stock options (without cost), we minority stockholders would enjoy "pebble" size stock share increments.

Very truly yours

/s/

John D. Corcoran, Jr.

CC: Prudential Financial
Kathleen M Gibson, VP & Secretary

Enclosures

[STAFF REPLY LETTER]

January 25, 2008

John D. Corcoran, Jr.
12 Berkshire Dr. West
Clifton Park, NY 12065

Re: Prudential Financial, Inc. Incoming letter dated January 12, 2008

Dear Mr. Corcoran:

This is in response to your letter dated January 12, 2008 concerning the shareholder proposal you submitted to Prudential Financial. On January 11, 2008, we issued our response expressing our informal view that Prudential Financial could exclude the proposal from its proxy materials for its upcoming meeting.

We received your letter after we issued our response. After reviewing the information contained in your letter, we find no basis to reconsider our position.

Sincerely,

/s/

Jonathan A. Ingram
Deputy Chief Counsel

cc: Kathleen M. Gibson
Vice President, Secretary, and Corporate Governance Officer
The Prudential Insurance Company of America
751 Broad Street, 21st Floor
Newark, NJ 07102