SecProbe.io

May 11, 2012

Via E-mail
Thomas Georgens  Chief Executive Officer and President NetApp, Inc. 495 East Java Drive Sunnyvale, California 94089
 Re: NetApp, Inc.
  Form 10-K for the Fiscal Year Ended April 29, 2011
  Filed June 23, 2011   File No. 0-27130   Response Letter Dated April 23, 2012
Dear Mr. Georgens:

We have reviewed your response letter  and have the following comments.
  Please respond to this letter within te n business days 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 circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.

General

1. You state in response to comme nt 1 in our letter dated D ecember 15, 2011 that so far you
have found no evidence that you or any of your s ubsidiaries directly exported products to
Syria.  Please tell us wh ether you, including any of your s ubsidiaries, have indirectly
exported products to Syria.  Provide us with  information about any transactions to which
you were a party if, as a direct  or indirect result of such transactions, your products were
delivered into Syria.  For example, tell us  whether, to your know ledge, understanding or
belief, products you sold to a th ird party vendor have been deli vered into Syria and, if so,
when you sold the products to the third pa rty vendor.  Tell us whether, to your
knowledge, understanding or belief , the products were resold to one or more additional
vendors before the products were delivered in to Syria, and whether you were involved in
any such vendor resale transactions.  Te ll us whether you had any knowledge of, or
reason to know, the final destination or end-us ers of the products.  Tell us also whether
any contract to which you were a party unde rlying the vendor resale transaction(s)
prohibited resale or provision of the produc ts into U.S.-designated state sponsors of
terrorism.

Thomas Georgens NetApp, Inc.
May 11, 2012
Page 2

2.  You state in response to comment 3 in our letter dated December 15, 2011 that certain of
your products are controlled items  included in the Commerce C ontrol List.  If it appears
to you that any of your products have been de livered into Syria, pl ease tell us whether
those products or their com ponents are controlled items included in the Commerce
Control List and, if so, desc ribe any potential military uses of those products or
components.
3. You state in response to comment 5 in our  letter dated December  15, 2011 that you have
notified OFAC and BIS regarding media re ports that your products may have been
shipped to Syria.  In your response to comment  6 you include the text of your related risk
factor.   Please represent to us that in futu re filings in which you include the related risk
factor you will disclose material developments in any current or future OFAC and/or BIS
proceedings regarding this and any associated matters.

Please contact Pradip Bhaumik, Special Couns el, at (202) 551-3333 or  me at (202) 551-
3470 if you have any questions abou t the comments or our review.
         S i n c e r e l y ,           /s/ Cecilia Blye          C e c i l i a  B l y e ,  C h i e f          Office of Global Security Risk  cc:  Barbara Jacobs   Assistant Director  Division of Cor poration Finance