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November 8, 2021
Brian T. Olsavsky
Chief Financial Officer
Amazon.com, Inc.
410 Terry Avenue North
Seattle, WA 98109
Re:Amazon.com, Inc.
Form 10-K for Fiscal Year Ended December 31, 2020
Response dated October 21, 2021
File No. 000-22513
Dear Mr. Olsavsky:
            We have reviewed your October 21, 2021 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 our
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 23, 2021 letter.
Form 10-K for Fiscal Year Ended December 31, 2020
General
1.Your response to comment 2 indicates that your capital expenditures and compliance costs
related to your journey to becoming net-zero carbon by 2040 have not been material.
Please explain in further detail how you determined that such capital expenditures were
not material and quantify the amounts incurred.  Your response should address your
sustainability initiatives in addition to your investments in renewable energy.  With
respect to compliance costs, please explain how you determined that the Federal Energy
Regulatory Commission licensing fees are not material and quantify any costs necessary
for you to make certain that your operations and assets comply with environmental laws
or regulations.

 FirstName LastNameBrian T. Olsavsky
 Comapany NameAmazon.com, Inc.
 November 8, 2021 Page 2
 FirstName LastName
Brian T. Olsavsky
Amazon.com, Inc.
November 8, 2021
Page 2
2.Your response to comment 3 indicates that while you do address demand for goods and
services that result in lower emissions through many aspects of your operations, you
have not identified trends in product demand attributable to climate-related regulation or
business trends, or competitive pressure arising from lower emission product offerings,
that are material to your operations or financial results.  Please provide additional detail
on how you determined that such regulation or business trends were not material.
3.With respect to reputational concerns related to operations or products that produce
greenhouse gas emissions, please explain how you determined that you have not seen
material effects on, or material trends affecting, your operations or financial results, as
stated in your response to prior comment 3.  Your response should more clearly explain
how you considered providing disclosure regarding climate change as a factor that could
affect your reputation or brand image.
4.Your response to comment 4 points to certain risk factors that you disclosed in your 2020
Form 10-K.  However, it does not appear that you have provided disclosure regarding the
effects of transition risks related to climate change.  Please revise to provide disclosure
that specifically addresses transition risks, such as those noted in your response, and
explains how such transition risks may impact your business, financial condition, and
results of operations.
            Please contact Cara Wirth at (202) 551-7127 or Lilyanna Peyser at (202) 551-3222 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Mark Hoffman