February 8, 2005

Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549

RE:
Huntsman Corporation
Common Stock and Mandatory Convertible Preferred Stock
File No. 333-120749, Form S-1

Dear Sirs:

In connection with the proposed offering of the above-captioned Securities, we wish to advise you that we hereby join with the Registrant's request that the effective date of the above-captioned Registration Statement be accelerated so that the same will become effective on February 10, 2005 at 3:30 p.m. or as soon as practicable thereafter.

Supplemental information supplied under Rule 418(a)(7) under the Securities Act of 1933:


(i)
 
Date of Preliminary Prospectus relating to the Common Stock: January 28, 2005
(ii)   Date of Preliminary Prospectus relating the Mandatory Convertible Preferred Stock: January 28, 2005
(iii)   Dates of distribution: January 28, 2005-February 8, 2005
(iv)   Number of prospective underwriters: 12
(v)   Number of prospectuses relating to the Common Stock distributed under (iv) above: approximately 39,300, of which 6 prospectuses were distributed to rating agencies
(vi)   Number of prospectuses relating to the Mandatory Convertible Preferred Stock distributed under (iv) above:
approximately 23,800, of which 330 prospectuses were distributed to institutional investors and 6 prospectuses were distributed to rating agencies
(vii)   Compliance with Rule 15c2-8 under the Securities Exchange Act of 1934: Included in Master Agreement Among Underwriters of Salomon Smith Barney Inc. (now known as Citigroup Global Markets Inc.).
Very truly yours,    

CITIGROUP GLOBAL MARKETS INC.
CREDIT SUISSE FIRST BOSTON LLC
DEUTSCHE BANK SECURITIES INC.
MERRILL LYNCH, PIERCE, FENNER & SMITH
                               INCORPORATED
As Representatives of the
Prospective Underwriters
 
 

CITIGROUP GLOBAL MARKETS INC.
 
 

By:
/s/  JEANNE CAMPANELLI      
Name: Jeanne Campanelli
Title: Director
 
 

CREDIT SUISSE FIRST BOSTON LLC
 
 

By:
/s/  FARLEY W. BOLWELL      
Name: Farley W. Bolwell
Title: Managing Director
 
 


DEUSTCHE BANK SECURITIES INC.
 
 

By:
/s/  JOEL D. FOOTE II      
Name: Joel D. Foote II
Title: Managing Director
 
 

By:
/s/  JOHN ANOS      
Name: John Anos
Title: Managing Director
 
 

MERRILL LYNCH, PIERCE, FENNER & SMITH
                               INCORPORATED
 
 

By:
/s/  PURNA R. SAGGURTI      
Name: Purna R. Saggurti
Title: Managing Director