August 13, 2024

Timothy S. Nicholls
Chief Financial Officer
International Paper Company
6400 Poplar Avenue
Memphis, Tennessee 38197

       Re: International Paper Company
           Form 10-K for the Year Ended December 31, 2023
           Filed February 16, 2024
           File No. 001-03157
Dear Timothy S. Nicholls:

       We have reviewed your July 30, 2024 response to our comment letter and 
have the
following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your 
response.

        After reviewing your response to this letter, we may have additional 
comments. Unless we
note otherwise, any references to prior comments are to comments in our June 
26, 2024 letter.

Form 10-K for the Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of 
Operations
Executive Summary, page 30

1.     Your response to prior comment 1 indicates that you have "excluded 
accelerated
       depreciation from special items used in the determination of non-GAAP 
measures"
       beginning with your Form 10-Q for the period ended June 30, 2024. 
However, the total
       amount of special items on page 3 of Exhibit 99.1 in your Form 8-K 
earnings release for
       June 30, 2024 furnished July 24, 2024 remains unchanged at $18 and $14 
before and after
       tax, respectively, for the three months ended March 31, 2024. We further 
note the
       earnings release line item "Closure costs" is the same amount as the 
previous line item for
       "Accelerated depreciation" and that, within the Form 10-Q, the 
accelerated depreciation
       amounts may now be included in the "Severance and other closure costs" 
line item
       presented on page 25. Since it appears as though only the titles and 
descriptions of the
       adjustment may have changed, please clarify how you have excluded 
accelerated
 August 13, 2024
Page 2

       depreciation.
       Please contact Heather Clark at 202-551-3624 or Andrew Blume at 
202-551-3254 if you
have questions regarding comments on the financial statements and related 
matters.



                                                        Sincerely,

                                                        Division of Corporation 
Finance
                                                        Office of Manufacturing