United States securities and exchange commission logo
March 6, 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
File No. 001-36743
Dear Luca Maestri:
We have limited our review of your filing to the financial
statements and related
disclosures 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.
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. You disclose that
services net sales increased due to higher net sales across all lines of
business. In the
December 30, 2023 Form 10-Q, you state that services net sales increased
in the first fiscal
quarter of fiscal 2024 compared to the same quarter in fiscal 2023 due
primarily to higher net
sales from advertising, video and cloud services. Further,
during the February 1,
2024 earnings call you referred to December quarter revenue
records for App Store
and AppleCare and state that paid subscriptions continue to grow
double-digits. Where
two or more factors contributed to a material change from period-to-
period, including any
offsetting factors, a quantitative discussion of such factors should be
included, and using
vague terms such as "primarily" in favor of specific quantification
should be avoided.
Please revise to include such quantitative discussion as it relates to
your services revenue
and provide us with a sample of any proposed revised disclosures
you intend to include
in future filings. Refer to Item 303(b) of Regulation S-K.
Luca Maestri
FirstName
Apple Inc. LastNameLuca Maestri
Comapany
March NameApple Inc.
6, 2024
March2 6, 2024 Page 2
Page
FirstName LastName
Notes to Consolidated Financial Statements
Note 2 - Revenue, page 35
2. You disclose net sales disaggregated by significant products and
services; however,
Services is presented as one line item. Based on your disclosures on
page 2, Services
includes advertising, AppleCare, cloud services, digital content and
payment
services. Please tell us how you considered these services to be
similar for purposes of
providing disclosures pursuant to ASC 280-10-50-40. As part of your
response, please
provide us with a breakout of services revenue by type of service for
each period
presented.
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.
Please contact Melissa Kindelan at 202-551-3564 or Kathleen Collins at
202-551-3499
with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Technology
cc: Sam Whittington