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SEC Company Response from AMAZON COM (AMZN) — May 20, 2010

AMAZON COM INC
Date: May 20, 2010 · CIK: 0001018724 · Accession: 0001193125-10-125145

AI Filing Summary & Sentiment

File numbers found in text: 000-22513

Date
May 20, 2010
Author
Assistant Director
Form
CORRESP
Company
AMAZON COM INC

Letter

United States Securities and Exchange Commission Division of Corporation Finance Filed January 29, 2010 Definitive Proxy Statement on Schedule 14A Filed April 14, 2010 File No. 000-22513

Dear Mr. Owings:

On behalf of Amazon.com, Inc. (the “Company”) and in connection with our response dated May 12, 2010 to your letter of April 27, 2010, regarding our Annual Report on Form 10-K for the year ended December 31, 2009 and Proxy Statement for our 2010 Annual Meeting of Shareholders, we acknowledge the following:

•

The Company is responsible for the adequacy and accuracy of the disclosure in the filings;

•

Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and

•

The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have any questions or further comments, please contact me at (206) 266-6360 (telephone) or (206) 266-7010 (facsimile).

Very truly yours,
/s/ Michael Deal

Show Raw Text
CORRESP
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filename1.htm

Correspondence Letter

 May 20, 2010

H. Christopher Owings

 Assistant Director

 United States Securities and Exchange Commission

Division of Corporation Finance

 Mail Stop 3561

 100 F Street, N.E.

 Washington, D.C.
20549-0405

Re:
Amazon.com, Inc.

Form 10-K for Fiscal Year Ended December 31, 2009

Filed January 29, 2010

Definitive Proxy Statement on Schedule 14A

Filed April 14, 2010

File No. 000-22513

 Dear
Mr. Owings:

 On behalf of Amazon.com, Inc. (the “Company”) and in connection with our response dated
May 12, 2010 to your letter of April 27, 2010, regarding our Annual Report on Form 10-K for the year ended December 31, 2009 and Proxy Statement for our 2010 Annual Meeting of Shareholders, we acknowledge the following:

•

 The Company is responsible for the adequacy and accuracy of the disclosure in the filings;

•

 Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the
filings; and

•

 The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of
the United States.

 If you have any questions or further comments, please contact me at (206) 266-6360
(telephone) or (206) 266-7010 (facsimile).

Very truly yours,

 /s/ Michael Deal

Michael Deal

Vice President and Associate General Counsel Amazon.com, Inc.

 1

cc:
Catherine Brown, Staff Attorney

Division of Corporation Finance

Yolanda Guobadia, Staff Accountant

Division of Corporation Finance

William Thompson, Branch Chief

Division of Corporation Finance

Thomas J. Szkutak

Senior Vice President and Chief Financial Officer

Amazon.com, Inc.

Shelley Reynolds

Vice President, Worldwide Controller and

Principal Accounting Officer

Amazon.com, Inc.

L. Michelle Wilson

Senior Vice President, General Counsel and Secretary

Amazon.com, Inc.

Ronald O. Mueller

Gibson, Dunn & Crutcher LLP

 2