SecProbe.io

January 28, 2011

Peter Oppenheimer  Senior Vice President and Chief Financial Officer
Apple, Inc.  1 Infinite Loop  Cupertino, California 95014
Re: Apple Inc.
Form 10-K for the Fiscal Year Ended September 25, 2010
Filed on October 27, 2010
File No. 000-10030

Dear Mr. Oppenheimer:
 We have reviewed your filing other than Part  III and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Supply of Components, page 7

1. You disclose that although most components essential to your bus iness are generally
available from multiple sources, you obtain certain key components from single or
limited sources which subjects you to significant supply and pric ing risks.  Please provide
additional disclosure regarding the identities of the single or limited source suppliers, the
nature of the dependency on such suppliers a nd your analysis under Item 601(b)(10) of
Regulation S-K of whether agreements with su ch single or limited source suppliers need
to be filed as exhibits to your annual report on Form 10-K.

Peter Oppenheimer  Apple, Inc. January 28, 2011 Page 2

 Item 3. Legal Proceedings, page 22

In re Apple & ATTM Antitrust Litigation, page 22
The Apple iPod iTunes Antitrust Litigation (forme rly Charoensak v. Apple Computer, Inc. and
Tucker v. Apple Computer, Inc.); Somers v. Apple Inc. , page 23
Vogel et al. v Jobs et al., page 23
2. In each legal proceeding, please disclose the id entity of the plaintiff and relief sought.
Please see Item 103 of Regulation S-K.
Mediostream, Inc. v. Acer America Corp. et al., page 22
Mirror Worlds, LLC. v. Apple Inc., page 22
3. In each legal proceeding, please describe the nature of each of the three patents involved
in these two legal proceedi ngs and the how the technology covered by such patents
relates to your business.  Pl ease also summarize the infringement claims in each of these
legal proceedings.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

Peter Oppenheimer  Apple, Inc. January 28, 2011 Page 3

 You may contact Phil Rothenberg at (202) 551-3466 if you have any questions regarding
these comments.  If you thereafter require as sistance, you may contact me at (202) 551-3462.

Sincerely,
  /s/ Mark P. Shuman
Mark P. Shuman
Branch Chief