United States securities and exchange commission logo




                                                                                
                               April 2, 2024

       Luca Maestri
       Chief Financial Officer
       Apple Inc.
       One Apple Park Way
       Cupertino, CA 95014

                                                        Re: Apple Inc.
                                                            Form 10-K for the 
fiscal year ended September 30, 2023
                                                            Response dated 
March 20, 2024
                                                            File No. 001-36743

       Dear Luca Maestri:

              We have reviewed your March 20, 2024 response to our comment 
letter and have the
       following comments.

              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 March 6, 2024
       letter.

       Form 10-K for the fiscal year ended September 30, 2023

       Management's Discussion and Analysis of Financial Condition and Results 
of Operations
       Products and Services Performance, page 22

   1.                                                   We note your response 
to prior comment 1. Please describe further the qualitative factors
                                                        considered in assessing 
the level of disclosures provided in your results of operations
                                                        discussion and 
specifically how you applied such factors to your current discussion of
                                                        changes in Services 
revenue.
       Notes to Consolidated Financial Statements
       Note 2 - Revenue, page 35

   2.                                                   We note your response 
to prior comment 2 that you believe the services included within
                                                        Services net sales to 
be similar in nature as they all represent services delivered to Apple
                                                        product customers 
related to Apple products. Please expand on your analysis supporting
 Luca Maestri
Apple Inc.
April 2, 2024
Page 2
      your conclusion that each of the various types of services within the    
Services    grouping
      are similar for the purpose of providing disclosures pursuant to ASC 
280-10-50-40. As
      part of your response, address the following:
          Expand on the descriptions of the various categories of services 
provided in your
           prior response, including the similarities and differences between 
them. For example,
           describe the specific type or types of advertising services and tell 
us how they are
           similar to or different from streaming or purchasing video and music 
media under
           digital content and extended warranty contracts and out-of-warranty 
repairs under
           AppleCare.
          Tell us how you considered differences in revenue recognition between 
each of the
           categories of services and reasons underlying such differences. For 
example, tell us
           how you considered differences between services where the company 
accounts for
           sales on a net basis (e.g., third-party application   related sales 
through the App Store)
           and those services you account for on a gross basis.
          Tell us how you considered differences in the customers for each 
category of your
           services. In this regard, you indicate advertising net sales are 
amounts earned from
           businesses for Apple customer activity on Apple products whereas 
Digital Content
           net sales are amounts earned from Apple customers for streaming or 
purchasing
           video, music, etc.
          Explain how you considered the quantitative significance of various 
categories of
           services.

       Please contact Melissa Kindelan at 202-551-3564 or Kathleen Collins at 
202-551-3499 if
you have any questions.



                                                             Sincerely,
FirstName LastNameLuca Maestri
                                                             Division of 
Corporation Finance
Comapany NameApple Inc.
                                                             Office of 
Technology
April 2, 2024 Page 2
cc:       Sam Whittington
FirstName LastName