SecProbe.io

Mail Stop 3561

October  1, 2018

Brian T. Olsavsky
Chief Financial Officer
Amazon.com Inc.
410 Terry Avenue North
Seattle, Washington  98109

Re: Amazon.com Inc.
 Form 10-Q for the Quarterly Period Ended June 30, 2018
Filed July 27, 2018
File No. 0 -22513

Dear Mr. Olsavsky :

We have reviewed  your August 30 , 2018  response to our comment letter and have the
following comment .  In our comment , we may ask you to provide us with information so we may
better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circu mstances, please tell us why in your response.

After reviewing your response to this comment , we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our August 13,
2018  letter .

Form 10-Q for the Quarterly Period Ended June 30, 2018

Note 1 – Accounting Policies

Revenue, page 8

1. We have reviewed your response to our prior comment four.  Based on your proposed
revised disclosures, it continues to be unclear when revenue related to thes e services is
recognized.  Please further revise your disclosures to clarify the following items by
reference to ASC 606 -10-50-12 and 606 -10-25-30:
 If true, please state that commissions for third -party seller services is recognized
when the products are s hipped.  In addition, please state when services related to
fulfillment and shipping are satisfied.

Brian T. Olsavsky
Amazon.com Inc.
October 1 , 2018
Page 2

  Discuss which services in your AWS arrangements are recognized at a point in time
and which are recognized over time.  In addition, for services recognized  at a point in
time, please disclose the particular point when revenue is recognized.
 Discuss the nature of your advertising services that are recognized at a point in time
and those that are recognized over time.  Tell us what consideration you gave to
recognizing revenue when impressions are delivered.

You may contact Tony Watson,  Accountant, at (202) 551 -3318 if you have questions
regarding comments on the financial statements and related matters.  Please contact Danilo
Castelli (Staff Attorney) at (202 ) 551 -6521 or Mara Ransom  (Assistant Director ) at (202) 551 -
3264 or me at (202) 551 -3344  with any other questions .

Sincerely,

 /s/ Jim Allegretto for

William H. Thompson
Accounting Branch Chief
Office of Consumer Products