SecProbe.io

March  4, 2015

Via E -mail
Mr. Luca Maestri
Chief Financial Officer
Apple Inc.
1 Infinite Loop
Cupertino, CA 95014

Re: Apple Inc.
 Form 10-K for the Fiscal Year Ended September 27, 2014
Filed October 27, 2014
File No. 000 -10030
Form 10 -Q for the Quarterly Period Ended December 27, 2014
Filed January 28, 2015
File No. 001 -36743

Dear Mr. Maestri :

We have reviewed your filing s and have the following comments.  Please note that we
have limited our review to only your financial statements and related disclosures.  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 advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances o r do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comment s, we may have  additional comments.

Form 10 -K for t he Fiscal Year Ended September 27, 2014

Management’s Discussion and Analysis of Financial Condition and Results of Operations

General

1. Throughout your discussion of the results of operations, you refer to various factors that
have impacted your results w ithout quantif ying the impact of each factor.   Where a
material change is attributed to two or more factors, including any offsetting factors, the
contribution of each identified factor should be described in quantified terms.  For

Mr. Luca Maestri
Apple Inc.
March  4, 2015
Page 2

 example, you attribute t he decrease in net sales and unit sales for the iPad in 2014 as a
result of growth in the Greater China and Japan segments offset by declines in all other
segments with no quantification.  As another example, you attribute the growth in the
Americas segmen t in 2014 as a result of increased net sales of iPhone, Mac and iTunes,
Software and Services offset by a decline in net sales of iPod and iPad and weakness in
foreign currencies but you do not quantify the effects of these individual factors.  Please
explain to us how you considered  quantifying the sources of material changes and
offsetting factors throughout your discussion.  Refer to Item 303(a)(3)(iii) of Regulation
S-K and Section III.D of SEC Release No. 33 -6835.

Product Performance , page 28

2. Please explain to us how you considered  expand ing your discussion in this section to
separately quantify and discuss factors responsible for changes in the levels of the
company’s cost of sales for your product categories and any known trends or
uncertaint ies that have had, or is reasonably expected to have, a mat erial favorable or
unfavorable impact on cost of sales by product category .  Similarly, we also note  your
segment level operating performance discussion does not include a presentation or
discussio n of changes in cost of sales .  Refer to Item 303(a)(3)(ii) of Regulation S -K and
Section III.B of SEC Release No. 33 -8350 .

Gross Margin , page 32

3. We note your discussion of changes in gross margin in 2014 that resulted from, among
others, the favorable s hift in mix to products with higher margins.  Considering the
significance of gross margin  to your operating results, please explain to us how you
considered  providing investors with a more comprehensive understanding of the material
components of this lin e item and the material factors impacting each of those
components, including quantifying the extent that each material factor has impacted gross
margin  as well as describing any known trends or uncertainties that have had or that you
reasonably expect wil l have a material favorable or unfavorable impact on product gross
margin.  As part of your response, explain to us how you considered  disclosing t he
relationship between revenues and cost of sales to also provide investors with an
understanding of what th e change in your product mix was and the corresponding impact
to gross margin .  Refer to Item 303(a)(3)(ii) and (iii) of Regulation S -K and Section III.B.
of SEC Release No. 33 -8350.

Mr. Luca Maestri
Apple Inc.
March  4, 2015
Page 3

 Notes to Consolidated Financial Statements

Note 1 – Summary of Significant Accounting Policies

Fair Value Measurements, page 55

4. You disclose that valuation techniques used to measure the fair value of the company’s
debt instruments and all other financial instruments were valued based on quoted market
prices or mode l driven valuations using significant inputs derived from or corroborated
by observable market data.   Please explain to us how you considered  expanding this
disclosure to include the specific valuation techniques used as well as examples of the
significan t inputs used in those valuations.  We refer you to ASC 820 -10-50-2bb.

Form 10 -Q for the Quarterly Period Ended December 27, 2014

Management Discussion and Analysis of Financial Condition an d Results of Operations, page 24

General

5. We note from your ch ange in segments discussed on page 22 that the results of your retail
stores are now included in each respective geographic segment and not reflected
separately.  We further note you no longer disclose the number of U.S. and international
stores, headcount , and the average number of open stores during the periods presented.
However, it appears such information, by geographic segment, may be material to
investors because the nature and risks of the retail business may differ from the rest of the
operations in each segment.  In this regard, your disclosures on page 15 of your Form 10 -
K for the year ended September 27, 2014 describe risks, investments and cost structures
unique to your retail business.  Further on page 8 of that filing, you disclose that more
than half of your employees work in the (former) retail segment.  Please explain to us
how you considered  presenting the retail sales and retail metrics for each geographic
segment . If you believe such information would not be material or integral to the
information disclosed by geographic segment , please explain.  Refer to Section III B of
SEC Release No. 33 -8350.

Notes to Condensed Consolidated Financial Statements

Note 11 – Segment Information and Geographic Data, page 22

6. We note your disclosure that in the first quarter of fiscal 2015, you began reporting
business performance and making decisions primarily on a geographic basis .  Please tell
us the specific facts and circumstances that resulted in the change to your reportable
operating segments, incl uding whether there were any changes to your management or
organizational structure and internal reporting  as well as the business purpose for the

Mr. Luca Maestri
Apple Inc.
March  4, 2015
Page 4

 change .  Please also tell us who your chief operating decision maker (CODM) is and
provide us with your analy sis in determining the CODM.  As part of your response,
please provide us with an organizational chart that includes the titles and roles and
responsibilities of the individuals who report to the CODM.  Refer to ASC 280 -10-50-5
through 9.

7. Please tell us what your operating segments are and whether any of your operating
segments are aggregated into a single or multiple reportable operating segment s.  If any
of your operating segments are aggregated into a single or multiple reportable operating
segment s, please provide us with your analysis in determining aggregation is appropriate
based on the guidance in ASC 280 -10-50-11.

8. Please tell us whether your CODM is provided discrete financial information or manages
and evaluates your business based on financial  results other than geography (e.g. type of
product, generation of product, gross margin by product, operating results within
geographic regions by product, etc.).  As part of your response , please tell us the specific
financial information provided to you r CODM that is used to make decisions about
resource allocation and performance assessment and your consideration of paragraphs 1
and 9 of ASC 280-10-50 in determining your operating segments.

We urge all persons who are responsible for the accurac y and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts re lating 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 provide  a written statement from the company
acknowledging that:

 the company is responsible f or 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 co mments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Mr. Luca Maestri
Apple Inc.
March  4, 2015
Page 5

 You may contact Melissa Kindelan, Staff Accountant  at (202) 551 -3564  if you have
questions  regarding comments on the financial statements and re lated matters.  Please contact me
at (202) 551 -3406  with any other questions.

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief