SecProbe.io

June 28, 2011
 Via E-mail

Mr. Peter Oppenheimer Senior Vice President and Chief Financial Officer Apple, Inc. 1 Infinite Loop Cupertino, California 95014
Re: Apple, Inc.
 Form 10-Q for the Quarter Ended March 26, 2011
Filed April 21, 2011 File No. 000-10030

Dear Mr. Oppenheimer:
 We have reviewed your filing and have the following comments.  We have limited our
review of your filing to those issu es we have addressed in the comments below.  In some of our
comments, we may ask you to provide 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.
            Form 10-Q for the Quarter Ended March 26, 2011

 Note 6.  Commitments and Contingencies

 Contingencies, page 18

 1. We note various news articles discussing the patent litigation sett lement between Nokia
and Apple.   Supplementally tell us the amount  and terms of such settlement agreement,
any amounts accrued, the periods in which they were recognized, and the timeline of the
negotiations with Nokia that led to the June settlement agreement.  Also, tell us how you
considered including a discussion regarding th is matter in your MD &A disclosures and
financial statement footnotes, including disclosu re of a reasonably possible range of loss
in excess of amounts accrued.  Further, tell us how considered disclosing this event in a
Form 8-K or tell us how you determined th at such disclosure was not necessary.

Mr. Peter Oppenheimer Apple, Inc. June 28, 2011 Page 2

2. With regard to the disclosures provided in your Forms 10-Q and Form 10-K, please
explain further the following:

 If there is at least a re asonable possibility that a loss exceeding amounts already
recognized may have been incurred you must either disclose the estimated additional
loss, or state that such an estimate ca nnot be made.  Please tell us, whether you
believe that it is reasonably po ssible that additional losses  would be material and, if
so, how your disclosures comply with pa ragraphs 3 through 5 of ASC 450-20-50 and
Question 2 of SAB Topic 5Y.  To the extent  that you have determined that it is
reasonably possible you will incur a loss in excess of the amounts already accrued,
but such amounts are not material, revise your disclosure to clearl y indicate as such.

 Tell us what you mean by the statement that  the company does not have a potential
liability related to any curre nt legal proceedings and clai ms. In this regard, explain
further what you mean by “potential liabili ty” and tell us how you determined that
your reference to “potential liability” complies with the terminology in ASC 450-20-
50 (e.g. probable, reasonably possibl e or remote loss contingency).

 Considering management’s assertions that  the company does not have any potential
liabilities that would have a material adverse affect on your financial condition or results of operations, please explain furt her your disclosures wh ere you indicate “[i]f
the Company failed to prevail in any of these legal matters or if several of these legal matters were resolved against the Company in the same reporting period, the
operating results of a particular reporti ng period could be materially adversely
affected.”  Tell us your consideration to clarify these disclosu res using terminology
within the guidance of ASC 450.  For in stance, revise to clarify whether you
determined that the likelihood of not prevai ling in any of these matters in the same
reporting period is remote, reasonably po ssible or probable. Also, tell us if you
omitted the statement of changes in stockhol ders’ equity and statement of cash flows
from your disclosures for a particular reason.
 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 an d accuracy of the disclo sure in the filing;

Mr. Peter Oppenheimer Apple, Inc. June 28, 2011 Page 3

  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 federa l securities laws of  the United States.

You may contact Megan Akst, Staff Accountant, at (202) 551-3407 or me at (202) 551-
3499 if you have questions.
Sincerely,
   /s/ Kathleen Collins
Kathleen Collins Accounting Branch Chief