United States securities and exchange commission logo

                              March 4, 2022

       Erica McLaughlin
       Senior Vice President and Chief Financial Officer
       Two Seaport Lane
       Suite 1400
       Boston, Massachusetts 02210

                                                        Re: CABOT CORP
                                                            Form 10-K for the
Fiscal Year Ended September 30, 2021
                                                            Filed November 29,
                                                            File No. 001-05667

       Dear Ms. McLaughlin:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended September 30, 2021

       Item 1. Business, page 4

   1.                                                   At the outset of Part
1, please provide prominent disclosure about the legal and
                                                        operational risks
associated with the company having substantial operations in China.
                                                        Your disclosure should
make clear whether these risks could result in a material change in
                                                        your operations and/or
the value of your securities or could significantly limit or
                                                        completely hinder your
ability to offer or continue to offer securities to investors and
                                                        cause the value of such
securities to significantly decline or be worthless. Your disclosure
                                                        should address how
recent statements and regulatory actions by China   s government, such
                                                        as those related to
data security or anti-monopoly concerns, have or may impact the
                                                        company   s ability to
conduct its business and/or accept foreign investments.
   2.                                                   Disclose each
permission or approval that you or your subsidiaries are required to obtain
 Erica McLaughlin
FirstName  LastNameErica McLaughlin
March      NameCABOT CORP
       4, 2022
March2 4, 2022 Page 2
FirstName LastName
         from Chinese authorities to operate your business and to offer
securities to foreign
         investors. State whether you or your subsidiaries are covered by
permissions requirements
         from the China Securities Regulatory Commission (CSRC), Cyberspace
Administration of
         China (CAC) or any other governmental agency, and state affirmatively
whether you have
         received all requisite permissions or approvals and whether any
permissions or approvals
         have been denied. Please also describe the consequences to you and
your investors if you
         or your subsidiaries: (i) do not receive or maintain such permissions
or approvals, (ii)
         inadvertently conclude that such permissions or approvals are not
required, or (iii)
         applicable laws, regulations, or interpretations change and you are
required to obtain such
         permissions or approvals in the future.
3.       Please revise your disclosure to provide a clear description of how
cash is transferred
         through your organization, addressing the following:
             Disclose your intentions to distribute earnings.
             Quantify any cash flows and transfers of other assets by type that
have occurred
             between the holding company and its Chinese subsidiaries, and the
direction of
             Quantify any dividends or distributions that a Chinese subsidiary
has made to the
             holding company and which entity made such transfer, and their tax
             Similarly, please quantify dividends or distributions made to U.S.
investors, the
             source, and their tax consequences. Your disclosure should make
clear if no transfers,
             dividends, or distributions have been made to date.
             Describe any restrictions on foreign exchange and your ability to
transfer cash
             between entities, across borders, and to U.S. investors.
             Describe any restrictions and limitations on your ability to
distribute earnings from
             the company, including your Chinese subsidiaries to the parent
company and U.S.
Item 1A. Risk Factors, page 14

4.       Please revise your risk factors section to specifically discuss risks
arising from the legal
         system in China, including risks and uncertainties regarding the
enforcement of laws and
         that rules and regulations in China can change quickly with little
advance notice. In this
         regarding we note the disclosure you have included on page 20, but ask
that you provide
         more detailed disclosure regarding the regulatory risks associated
with your operations
         and revenue from China.
5.       In light of recent events indicating greater oversight by the
Cyberspace Administration of
         China (CAC) over data security, please revise your disclosure to
explain if and how this
         oversight impacts your business and to what extent you believe that
you are compliant
         with the regulations or policies that have been issued by the CAC to
date, if applicable.
       In closing, 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.
 Erica McLaughlin
March 4, 2022
Page 3

       You may contact Jeanne Bennett at (202) 551-3606 or Julie Sherman at
(202) 551-3640 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Margaret Schwartz at (202) 551-7153 or Laura Crotty at (202) 551-7614
with any other

FirstName LastNameErica McLaughlin                       Sincerely,
Comapany NameCABOT CORP
                                                         Division of
Corporation Finance
March 4, 2022 Page 3                                     Office of Life
FirstName LastName