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CORRESP Filing

COSTCO WHOLESALE CORP /NEW
Date: May 15, 2025 · CIK: 0000909832 · Accession: 0000909832-25-000030

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File numbers found in text: 000-20355

Date
May 15, 2025
Author
Gary Millerchip
Form
CORRESP
Company
COSTCO WHOLESALE CORP /NEW

Letter

Document Writer’s Direct Number: (425) 313-2060 Fax: (425) 313-6800 May 15, 2025 BY EDGAR Patrick Kuhn and Lyn Shenk Division of Corporation Finance Office of Trade & Services Securities and Exchange Commission 100 F Street N.E. Washington, D.C. 20549 Re: Costco Wholesale Corporation -- Form 10-K for the Fiscal Year Ended September 1, 2024, Response dated April 21, 2025 -- File No. 000-20355 Dear Mr. Kuhn and Mr. Shenk: In response to your letter of May 12, 2025 (the “Letter”), please see the discussion below, which corresponds to the paragraph in your letter. Form 10-K for the Fiscal Year Ended September 1, 2024 Business Memberships, page 5 1. We note your response to prior comment 1 and 3. Please clarify your disclosure so users have better understanding of your rational behind the methodology of your renewal rate calculation and active memberships. Response: We will revise our disclosures in our next Annual Report on Form 10-K to clarify the rationale behind the methodology of our renewal rate calculation and active memberships. Please contact me if you have any questions or further comments. Sincerely, COSTCO WHOLESALE CORPORATION /s/ GARY MILLERCHIP Gary Millerchip Executive Vice President and Chief Financial Officer

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CORRESP
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 Document Writer’s Direct Number: (425) 313-2060 Fax: (425) 313-6800 May 15, 2025 BY EDGAR Patrick Kuhn and Lyn Shenk Division of Corporation Finance Office of Trade & Services Securities and Exchange Commission 100 F Street N.E. Washington, D.C. 20549 Re: Costco Wholesale Corporation -- Form 10-K for the Fiscal Year Ended September 1, 2024, Response dated April 21, 2025 -- File No. 000-20355 Dear Mr. Kuhn and Mr. Shenk: In response to your letter of May 12, 2025 (the “Letter”), please see the discussion below, which corresponds to the paragraph in your letter. Form 10-K for the Fiscal Year Ended September 1, 2024 Business Memberships, page 5 1. We note your response to prior comment 1 and 3. Please clarify your disclosure so users have better understanding of your rational behind the methodology of your renewal rate calculation and active memberships. Response: We will revise our disclosures in our next Annual Report on Form 10-K to clarify the rationale behind the methodology of our renewal rate calculation and active memberships. Please contact me if you have any questions or further comments. Sincerely,      COSTCO WHOLESALE CORPORATION /s/    GARY MILLERCHIP Gary Millerchip Executive Vice President and Chief Financial Officer