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February 23, 2024
Sandeep S. Aujla
Executive Vice President and Chief Financial Officer
Intuit Inc.
2700 Coast Avenue
Mountain View, CA 94043
Re:Intuit Inc.
Form 10-K for the fiscal year ended July 31, 2023
File No. 000-21180
Dear Sandeep S. Aujla:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the fiscal year ended July 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 37
1.We note that in your earnings call for the quarter ended October 31, 2023, your CEO
indicated that the company looks at metrics around number of customers, conversion,
retention and average revenue per customer (ARPC) across the entire franchise, as well as
by area and that the metric that will matter the most for Full Service is going to be
ARPC. We also note that in your earnings release for the quarter ended July 31, 2023
you disclosed TurboTax Federal Unit Data. Please tell us whether these metrics are key
performance indicators used in managing your business and if so, please include a
quantified discussion of these metrics for each period presented in your periodic filings.
Refer to SEC Release No. 33-10751.

 FirstName LastNameSandeep S. Aujla
 Comapany NameIntuit Inc.
 February 23, 2024 Page 2
 FirstName LastName
Sandeep S. Aujla
Intuit Inc.
February 23, 2024
Page 2
Segment Results, page 39
2.We note your discussion of segment results, starting on page 37, describes multiple factors
that impacted results in each reporting period, however, you provide no quantification of
the impact of each factor. For example:

•You disclose that Online Ecosystem revenue increased due to an increase in
customers, higher effective prices and a shift in mix to higher-priced offerings as well
as higher Mailchimp revenue.
•The operating income discussion for the Small Business & Self-Employed segment
describes the year-over-year increase as primarily due to increase in revenue and
partially offset by higher staffing expenses, sales-related expenses, and outside
services expenses.
•Revenue for the Consumer segment discussion describes the increase as primarily
due to a shift in mix to your higher-priced product offerings as well as higher
effective prices, partially offset by a decrease in total tax returns.

Where a material change is attributed to two or more factors, including any offsetting
factors, please revise throughout your results of operations discussion to ensure you
include a quantified discussion of each factor and avoid using terms such as "primarily" or
"substantially all" in favor of specific quantification. Similar concerns apply to your
Forms 10-Q. Refer to Item 303(b) of Regulation S-K.
            In closing, 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 Chen Chen at 202-551-7351 or Christine Dietz at 202-551-3408 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Kerry McLean