UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4561 DIVISION OF CORPORATION FINANCE March 14,2012 Denise A. Home McDonald's Corporation denise_
[email protected] Re: McDonald's Corporation Incoming letter dated January 24,2012 Dear Ms. Home: This is in response to your letters dated January 24, 2012, February 9,2012, and March 9, 2012 concerning the shareholder proposal submitted to McDonald's by John Harrington. We also have received letters on the proponent's behalf dated February 28,2012 and March 13,2012. Copies ofall ofthe correspondence on which this response is based will be made available on our website at http://www.sec.gov/divisions/corpfinlcf-noactionl14a-8.shtml. For your reference, a brief discussion ofthe Division's informal procedures regarding shareholder proposals is also available at the same website address. Sincerely, TedYu Senior Special Counsel Enclosure cc: Sanford J. Lewis
[email protected] March 14,2012 Response of the Office of Chief Counsel Division of Corporation Finance Re: McDonald's Corporation Incoming letter dated January 24,2012 The proposal requests that the board issue a report assessing the company's policy responses to growing evidence oflinkages between fast food and childhood obesity, diet related diseases and other impacts on children's health. The proposal also specifies that the report should include an assessment ofthe potential impacts ofpublic concerns and evolving public policy on the company's finances and operations. We are unable to concur in your view that McDonald's may exclude the proposal under rule 14a-8(i)(10). Based on the information you have presented, it does not appear that McDonald's public disclosures compare favorably with the guidelines ofthe proposal.