SecProbe.io

Mail Stop 3561

November 24 , 2017

Jeffrey P. Bezos
Chairman and Chief Executive Officer
Amazon.com, Inc.
410 Terry Avenue North
Seattle, Washington 98109 -5210

Re:      Amazon.com, Inc.
Form 10 -K for the Fiscal Year Ended December 31, 2016
Response Dated October 26, 2017
File No. 0-22513

Dear Mr. Bezos :

We have reviewed your October 26, 2017 response to our comment letter 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 ou r
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.
Unless we note otherwise, our references to prior comments are to comments in our September
27, 2017  letter.

Form 10 -K for the Fiscal Year Ended December 31, 2016

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

Results of Operations

Net Sales, page 23

1. We note your response to comment 1 and you r statement that “growth in overall unit
sales has been the primary driver of net sales across the many and expanding product
categories and services sold through [y]our website, and [you] have not identified
individual drivers within Media or EGM.”  Given  the many product categories and
services sold through your website and the continued increase in net sales, which you

Jeffrey P. Bezos
Amazon.com, Inc.
November 24 , 2017
Page 2

 attribute primarily to increased unit sales, please disclose whether you have identified
individual drivers or trends in any product cate gory with a view to enhancing an
understanding of where you are experiencing increases in sales.  If increased unit sales
are not attributable to any particular product category and are instead reflective of largely
uniform increases in unit sales across a ll of your product categories, please state as much.

Notes to Consolidated Financial Statements

Note 1 – Description of Business and Accounting Policies

Technology and Content, page 43

2. We reviewed your response to comment 3.  As previously requested,  please disclose the
total amount of research and development costs charged to expense for each year
presented in the consolidated statements of operations as required by ASC 730 -10-50-1.
In making your determination of what constitutes research and devel opment, please
consider the activities typically considered research and development as set forth in ASC
730-10-55-1.  In addition, please describe to us in detail the nature of the expenditures
that you determined meet the definition of research and devel opment costs and walk us
through your reasoning process in your determination of research and development costs
to the extent such activities are not encompassed by the examples provided in ASC 730 -
10-55-1.  Please provide a similar narrative to us regardi ng your determination of
research and development activities charged to the AWS segment.

You may contact  Ta Tanisha Meadows, Staff Accountant  at (202) 551 -3322 or me at
(202) 551 -3344 if you have questions regarding comments on the financial statements and
related matters.  Please contact Danilo Castelli, Staff Attorney  at (202) 551 -6521  or Lilyanna
Peyser, Special Counsel  at (202) 551 -3222  with any other questions.

Sincerely,

/s/ William H. Thompson

William H. Thompson
Accounting Branch Chief
Office of Consumer Products

cc:  Shelley Reynolds , Vice President and Worldwide Controller