Inclusion Criteria:

- Patients must have histologically or cytologically confirmed diagnosis of non-small
cell lung cancer

- Patients must have surgically unresectable stage IIIA disease or stage IIIB disease
without malignant pleural/pericardial effusion

- Patients must have measurable disease as per the RECIST criteria, defined as at least
one lesion that can be accurately measured in at least one dimension (longest
diameter to be recorded) as >20 mm with conventional techniques or as >10 mm with
spiral CT scan. See section 9.2 for the evaluation of measurable disease.

- Age >18 years. Lung cancer is extremely rare in children.

- ECOG performance status 0-1 (Karnofsky >70%; see Appendix A).

- If available, tumor tissue should be submitted for EGFR status by IHC and correlative
studies.

- Patients must have normal organ and marrow function as defined below:

- leukocytes >3,000/μL

- absolute neutrophil count >1,500/μL

- platelets >100,000/μL

- total bilirubin within normal institutional limits

- AST(SGOT)/ALT(SGPT) <2.5 X institutional upper limit of normal

- creatinine within normal institutional limits OR

- creatinine clearance >60 mL/min/1.73 m2 for patients with creatinine levels above
institutional normal

- The effects of cetuximab on the developing human fetus at the recommended therapeutic
dose are unknown. For this reason and because EGFR inhibitors, chemotherapeutic
agents and radiation therapy, as well as other therapeutic agents used in this trial
are known to be teratogenic, women of child-bearing potential and men must agree to
use adequate contraception (hormonal or barrier method of birth control; abstinence)
prior to study entry and for the duration of study participation. Should a woman
become pregnant or suspect she is pregnant while participating in this study, she
should inform her treating physician immediately.

- Patients must either be not of child bearing potential or have a negative pregnancy
test within 7 days of treatment. Patients are considered not of child bearing
potential if they are surgically sterile (they have undergone a hysterectomy,
bilateral tubal ligation, or bilateral oophorectomy) or they are postmenopausal.

- Willingness to sign an approved informed consent.

Exclusion Criteria:

- Patients should not have received prior chest radiation therapy.

- Patients with a history of pulmonary fibrosis are excluded from study.

- Patients may not be receiving any other investigational agents.

- History of allergic reactions attributed to compounds of similar chemical or biologic
composition to carboplatin, paclitaxel, cetuximab or other agents used in the study.

- History of any cancer other than NSCLC (except non-melanoma skin cancer or carcinoma
in situ of the cervix) within the last five years.

- Prior therapy with known specific inhibitors of the EGFR.

- History of severe allergic reaction to prior therapy with monoclonal antibodies

- Peripheral neuropathy of more than grade 1 in severity

- Uncontrolled intercurrent illness including, but not limited to, ongoing or active
infection, significant history of uncontrolled cardiac disease ie. uncontrolled
hypertension, unstable angina, recent myocardial infarction (within prior 6 months),
uncontrolled congestive heart failure,and cardiomyopathy with decreased ejection
fraction, or psychiatric illness/social situations that would limit compliance with
study requirements.

- Pregnant women are excluded from this study because carboplatin, paclitaxel,
cetuximab and radiation therapy have the potential for teratogenic or abortifacient
effects. Because there is an unknown but potential risk for adverse events in
nursing infants secondary to treatment of the mother with the above agents,
breastfeeding should be discontinued if the mother is treated with the agents used in
this study. These potential risks may also apply to other agents used in this study.

- Patients with immune deficiency are at increased risk of lethal infections when
treated with marrow-suppressive therapy. Therefore, HIV-positive patients receiving
combination anti-retroviral therapy are excluded from the study because of possible
pharmacokinetic interactions with carboplatin, paclitaxel and cetuximab or other
agents administered during the study. Appropriate studies will be undertaken in
patients receiving combination anti-retroviral therapy when indicated.

- Active hepatitis.

- History of pulmonary fibrosis.