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        March 19, 2010
 Peter Oppenheimer  Senior VP and Chief Financial Officer Apple Inc. 1 Infinite Loop Cupertino, CA  95014
 Re: Apple Inc.
Form 10-K/A for the Fiscal Year Ended September 26, 2009
Filed on January 25, 2010
  File No. 000-10030

Dear Mr. Oppenheimer:
We have reviewed your response letter  dated March 4, 2010 in connection with
the above-referenced filing and have the followi ng comments.  If indicated, we think you
should revise your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as deta iled as necessary in your expl anation.  In some of our
comments, we may ask you to provide us w ith supplemental information so we may
better understand your disclosure.  After re viewing this information, we may raise
additional comments.  Unless otherwise noted, where prior comments are referred to they
refer to our letter dated February 18, 2010.

Form 10-K/A for the Fiscal Year Ended September 26, 2009

Note 1. Summary of Significant Accounting Policies, Revenue Recognition, page 29
1. We note your response to prior comment 1.  Please tell us if you considered
specifying in your disclosures what pr oducts you considered to be “similar
offerings” in determining the estimated se lling price of unspecified upgrades for
the iPhone and Apple TV (e.g., specified software upgrades sold for the iPod
Touch and AppleCare).
2. In your iPhone and Apple TV arrangem ents, please tell us if related sales
incentives, if any, mainly include thos e consisting of volume purchase discounts

Peter Oppenheimer
Apple Inc. March 19, 2010 Page 2
and/or discounts offered for purchasing speci fic products and/or services together.
If you provide sales incentiv es for these products, tell us if you believe they
mainly relate to the delivered item or both the delivered and the undelivered (i.e.,
unspecified software upgrades) items.
3. Please refer to prior comment 3 and tell us if you considered specifying in your
Revenue Recognition for Arrangements with  Multiple Deliverables policy that
your software arrangements containing multiple elements primarily include
transactions involving the sa le of APP and MobileMe.

* * * * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.
 You may contact Melissa Fe ider, Staff Accountant, at  (202) 551-3379 or me at
(202) 551-3499 if you have any questions  regarding the above comments.
        S i n c e r e l y ,           Kathleen Collins
Accounting Branch Chief