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Correspondence

 U.S. Securities and Exchange Commission

Confidential Treatment Requested by Apple Inc.

April 1, 2015

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 FOIA CONFIDENTIAL TREATMENT REQUESTED

Apple Inc.

April 1, 2015

1 Infinite Loop

Cupertino, CA 95014

 BY EDGAR AND HAND DELIVERY

To:
 Patrick Gilmore

 Accounting Branch Chief

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549

Re:
 Apple Inc.

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

 Filed on October 27, 2014

 File No. 000-10030

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

 Filed on January 28, 2015

 File No. 001-36743

Dear Mr. Gilmore,

 Apple Inc. (the “Company”) provides
the following response (the “Response Letter”) to the comments contained in the letter (the “Comment Letter”) of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange
Commission (the “SEC” or “Commission”), dated March 4, 2015, relating to the above-referenced filings.

 Because of the
commercially sensitive nature of information contained herein, the Company has filed a separate letter (the “Request Letter”) with the Office of FOIA Services in connection with a request for confidential treatment of certain portions of
this Response Letter under the Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”), 17 C.F.R. § 200.83 (“Rule 83”), and the Commission’s rules and regulations promulgated under FOIA. For the Staff’s reference,
the Company has enclosed a copy of the Request Letter with this copy of the correspondence marked to show the portions redacted from the version filed via EDGAR and for which the Company is requesting confidential treatment.

In accordance with Rule 83, the Company requests confidential treatment of (a) the marked portions (the “Confidential Information”) of
this Response Letter and (b) the accompanying Request Letter (collectively, the “Confidential Material”). Please promptly inform the undersigned of any request for disclosure of the Confidential Material made pursuant to FOIA or
otherwise so that the undersigned may substantiate the foregoing request for confidential treatment in accordance with Rule 83.

 In accordance
with Rule 83, this Response Letter has also been clearly marked with the legend “Confidential Treatment Requested by Apple Inc.” and each page is marked for the record with the identifying numbers and code “AI-001” through
“AI-012.”

 In response to the Comment Letter, and to facilitate review, the Company has repeated the text of each of the Staff’s
comments below and followed each comment with the Company’s response.

Confidential Treatment Requested by Apple Inc.

 AI-001

*** - Information omitted and provided under separate cover to the Staff pursuant to Rule 83

 U.S. Securities and Exchange Commission

Confidential Treatment Requested by Apple Inc.

 April 1, 2015

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Form 10-K for the 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 without quantifying 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 example, you attribute the 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 segment 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.

 The
Company respectfully advises the Staff that when preparing the discussion and analysis of results of operations in Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”) it analyzes its
results of operations based on the instructions and guidance in Item 303(a)(3)(iii) of Regulation S-K. The Company notes in particular Instruction 4 to Item 303(a), which states “Where the consolidated financial statements reveal
material changes from year to year in one or more line items, the causes for the changes shall be described to the extent necessary to an understanding of the registrant’s businesses as a whole; Provided, however, That if the causes for
a change in one line item also relate to other line items, no repetition is required and a line-by-line analysis of the financial statements as a whole is not required or generally appropriate. Registrants need not recite the amounts of changes from
year to year which are readily computable from the financial statements”, and Section III.D of SEC Release No. 33-6835 (“Release 33-6835”), which states further that “An analysis of changes in line items is required where
material and where the changes diverge from changes in related line items of the financial statements, where identification and quantification of the extent of contribution of each or two or more factors is necessary to an understanding of a
material change, or where there are material increases or decreases in net sales or revenue” (emphasis added).

In summary, the Company’s MD&A analysis determined the net sales financial statement line item was the most
important information for investors to understand its operating performance and, accordingly, the Company provided in its MD&A net sales by operating segment and net sales and unit sales by product. The Company then evaluated whether there had
been material changes in the cost of sales and gross margin financial statement line items and whether those changes diverged from the change in net sales. The Company determined the material changes in cost of sales and gross margin to be
consistent with the change in net sales. Next, the Company noted the research and development (“R&D”) and selling, general and administrative (“SG&A”) financial statement line items, combined, represented approximately
13.8% of total expenses and less than 10% of net sales. As changes in those financial statement line items did not diverge from the change in net sales and did not have a material impact on operating results, the Company did not consider the changes
in those financial statement line items material to its operating results. Similarly, given the balance involved, the Company did not consider the other income/(expense), net financial statement line item material to the overall financial results of
the Company. Finally, the Company determined the change in the provision for income taxes financial statement line item was consistent with the change in the income before provision before income taxes financial statement line item.

The Company provides below the specifics of its MD&A analysis of the results of operations for the fiscal year ended
September 27, 2014 to determine which line item required further discussion and analysis in its MD&A.

 Confidential Treatment Requested by Apple Inc.

AI-002

 *** - Information omitted
and provided under separate cover to the Staff pursuant to Rule 83

 U.S. Securities and Exchange Commission

Confidential Treatment Requested by Apple Inc.

 April 1, 2015

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 Net sales

Net sales increased from $170.9 billion in 2013 to $182.8 billion in 2014, an $11.9 billion year-over-year increase.
[***]

 To quantify the factors that resulted in the net sales increase, the Company provided detailed disclosure of
net sales by product for 2013 and 2014, as disclosed on page 27 of the Company’s Form 10-K for the year ended September 27, 2014 (the “2014 Form 10-K”). The Company notes iPhone net sales increased $10.7 billion, or 11.7%, from
2013 to 2014. The $10.7 billion increase in year-over-year iPhone net sales represented 90% of the increase in the Company’s total net sales. [***] The Company nonetheless provided both a tabular and narrative discussion of the components that
impacted net sales, including those cited as examples in the Staff’s comment.

 To further analyze the iPhone
net sales increase, the Company provided detailed disclosure of unit sales by product for 2013 and 2014, as disclosed on page 27 of the 2014 Form 10-K. The Company notes iPhone unit sales increased from 150.3 million units in 2013 to
169.2 million units in 2014, or 12.6%.

 [***] The Company notes that, in accordance with
Item 303(a)(3)(iii) of Regulation S-K, the Company’s disclosure in its 2014 Form 10-K also highlighted that the year-over-year growth in iPhone net sales and unit sales in 2014 resulted primarily from the successful introduction and launch
of new iPhones.

 Cost of sales

Cost of sales increased from $106.6 billion in 2013 to $112.3 billion in 2014, a $5.7 billion year-over-year increase.
[***]

 Gross margin

Gross margin increased from $64.3 billion in 2013 to $70.5 billion in 2014, a $6.2 billion year-over-year increase.
[***] As a result, the Company provided a narrative discussion of the components that impacted gross margin on page 32 of the 2014 Form 10-K. [***]

Research and development

R&D expense increased from $4.5 billion in 2013 to $6.0 billion in 2014, a $1.6 billion year-over-year increase.
[***] Additionally, R&D expense, as a percentage of the Company’s total net sales, has remained consistent year-over-year. As a result, the Company provided a narrative discussion of the components that impacted R&D expense on page 33
of the 2014 Form 10-K. [***]

 Confidential Treatment Requested by Apple Inc.

AI-003

 *** - Information omitted
and provided under separate cover to the Staff pursuant to Rule 83

 U.S. Securities and Exchange Commission

Confidential Treatment Requested by Apple Inc.

 April 1, 2015

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 Selling, general and administrative

SG&A expense increased from $10.8 billion in 2013 to $12.0 billion in 2014, a $1.2 billion year-over-year increase.
[***] Additionally, SG&A expense, as a percentage of the Company’s total net sales, has remained consistent year-over-year. As a result, the Company provided a narrative discussion of the components that impacted SG&A expense on page 33
of the 2014 Form 10-K. [***]

 Other income/(expense), net

Other income/(expense), net decreased from $1.2 billion in 2013 to $980 million in 2014, a $176 million year-over-year
decrease. [***] The year-over-year decrease in other income/(expense), net was equivalent to 0.4% of the previous year’s income before provision for income taxes. [***] As a result, the Company provided a narrative discussion of the components
that impacted other income/(expense), net on page 34 of the 2014 Form 10-K. [***]

 Provision for income taxes

Provision for income taxes increased from $13.1 billion in 2013 to $14.0 billion in 2014, an $855 million year-over-year
increase. [***] The year-over-year increase in provision for income taxes was equivalent to 1.7% of the previous year’s income before provision for income taxes (essentially a 10 basis point decrease in the effective tax rate from 26.2% in 2013
to 26.1% in 2014). [***]

 Accordingly, with respect to the discussion of the Company’s results of operations,
as well as any other material changes in the Company’s financial statements, management has reviewed Item 303(a)(3)(iii) of Regulation S-K and Release 33-6835 and believes its disclosures are appropriate. Consistent with the Staff’s
comment, the Company will continue to monitor its results of operations and disclose any material amounts for individual factors as appropriate.

Confidential Treatment Requested by Apple Inc.

AI-004

 *** - Information omitted
and provided under separate cover to the Staff pursuant to Rule 83

 U.S. Securities and Exchange Commission

Confidential Treatment Requested by Apple Inc.

 April 1, 2015

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

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

Product Performance, page 28

2.
 Please explain to us how you considered expanding 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 uncertainties that have had, or is reasonably expected to have, a material 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 discussion 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.

 The
Company respectfully advises the Staff that the Product Performance section of the Company’s MD&A in the 2014 Form 10-K is included to provide the reader with a more detailed understanding of the factors that drove net sales performance for
the year. As noted above in the Company’s response to Comment 1, net sales was the only financial statement line item that was considered to have changed materially, and the Company did not consider a 5.3% year-over-year increase in the cost of
sales financial statement line item to be a material change, as cost of sales has a direct relationship to net sales (i.e., the change in cost of sales did not materially diverge from the change in net sales). While the Company believes the material
change in net sales was sufficiently explained by the inclusion of information on net sales and unit sales by product, it has provided an additional narrative discussion of net sales in the Product Performance and Segment Operating Performance
sections of the Company’s MD&A. Section III.B of SEC Release No. 33-8350 (“Release 33-8350”) notes that “Segment discussion and analysis should be designed to avoid unnecessary duplication and immaterial detail that is
not required and does not promote understanding of a company’s overall financial condition and operating performance.” Accordingly, the Company does not believe a presentation or discussion of changes in cost of sales by product would be
informative to the reader of the financial statements. To the extent changes in cost of sales within a product category have a material impact on cost of sales and/or gross margin, the Company would analyze it in its disclosure. The Company also
would consider, and would disclose, the extent to which cost of sales of a segment contribute to materially disproportional changes between net sales and operating income within that segment consistent with the guidance in Release 33-6385.

The Company does consider the guidance in Item 303(a)(3)(ii) of Regulation S-K and Release 33-8350 when preparing
its MD&A and historically has discussed items that were considered known trends or uncertainties that had, or were reasonably expected to have, a material impact on a financial statement line item. As an example, in the Company’s Form 10-K
for the year ended September 28, 2013, the Company highlighted that the iPad mini had a gross margin significantly below the Company’s average product margins. In another example, in the Company’s Form 10-Q for the quarterly period
ended December 27, 2014 (“Q1 2015 Form 10-Q”), the Company identified and discussed a longer repurchase cycle and some level of cannibalization leading to a decrease in iPad sales. Consistent with the Staff’s comment, the Company
will continue to monitor its results of operations and disclose any known trends or uncertainties as appropriat