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September 24, 2021
Kevin R. Johnson
President and Chief Executive Officer
Starbucks Corporation
2401 Utah Avenue South
Seattle, WA 98134
Re:Starbucks Corporation
Form 10-K for Fiscal Year Ended September 27, 2020
Filed November 12, 2020
File No. 000-20322
Dear Mr. Johnson:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
1.We note that you provided more expansive disclosure in your CSR report than you
provided in your SEC filings.  Please advise us what consideration you gave to providing
the same type of climate-related disclosure in your SEC filings as you provided in your
CSR report.
2.To the extent material, discuss the indirect consequences of climate-related regulation or
business trends, such as the following:
•decreased demand for goods or services that produce significant greenhouse gas
emissions or are related to carbon-based energy sources;
•increased competition to develop innovative new products that result in lower
emissions; and
•any anticipated reputational risks resulting from your operations or those of the
business partners in your supply chain related to material greenhouse gas emissions.
3.If material, discuss the significant physical effects of climate change on your operations
and results, including the quantification of material weather-related damages to your
property or operations and any weather-related impacts on the cost or availability of

 FirstName LastNameKevin R. Johnson
 Comapany NameStarbucks Corporation
 September 24, 2021 Page 2
 FirstName LastName
Kevin R. Johnson
Starbucks Corporation
September 24, 2021
Page 2
insurance.
4.Disclose any material litigation risks related to climate change and the potential impact to
the company.
5.Quantify any material increase in compliance costs related to climate change.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Cara Wirth at (202) 551-7127 or Lilyanna Peyser at (202) 551-3222 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       JT Ho