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 March 18, 2026

Rebecca House
Senior Vice President
ROCKWELL AUTOMATION, INC
1201 South Second Street
Milwaukee, Wisconsin 53204

 Re: ROCKWELL AUTOMATION, INC
 10-K filed November 12, 2025 File No. 001-12383
Dear Rebecca House:

 We have reviewed your filing and have the following comments. Please
respond to this
letter 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 a comment applies to your
facts and
circumstances, please tell us why in your response. After reviewing your
response to this letter,
we may have additional comments.

Form 10-K for the Fiscal Year Ended September 30, 2025
Management's Discussion and Analysis
Total segment operating earnings, page 24

1. We note your presentation of total segment operating earnings. When this
measure is
 presented outside of the ASC 280 disclosures in the notes to the
financial statements, it
 must comply with all non-GAAP guidance. In this regard, please address
the following:
 This measure excludes corporate and other costs. As such, it appears
to exclude
 normal, recurring, cash operating expenses and, as such, does not
comply with Rule
 100(b) of Regulation G and Item 10(e) of Regulation S-K. Refer also
to Question
 100.01 of the Division of Corporation Finance s Compliance &
Disclosure
 Interpretations on Non-GAAP Financial Measures.
 This measure excludes purchase accounting depreciation and
amortization, which
 results in a measure that reflects part, but not all, of an
accounting concept and
 therefore substitutes individually tailored recognition and
measurement
 methods. Refer to Question 100.04 of the Division of Corporation
Finance s
 Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures.
 Confirm you will no longer include this measure outside of your ASC 280
disclosures in
 future filings, including earnings releases filed under Form 8-K or
revise your measure to
 remove these adjustments. Note that if you you continue to include this
measure as
 appropriately revised, the reconciliation should start with net income,
the most directly
 comparable GAAP measure.
 March 18, 2026
Page 2

2. We note your presentation of total segment operating margin. In addition
to addressing
 the above comments related to total segment operating earnings, please
revise to disclose
 the most directly comparable GAAP measure, operating income margin, with
equal or
 greater prominence as required by Item 10(e)(1)(i)(A) of Regulation S-K
and Question
 102.10 of the Division of Corporation Finance s Compliance &
Disclosure
 Interpretations on Non-GAAP Financial Measures.
Adjusted Income, Adjusted EPS, and Adjusted Effective Tax Rate Reconciliation,
page 30

3. We note you exclude purchase accounting depreciation and amortization
from your non-
 GAAP measures Adjusted Income, Adjusted EPS and Adjusted Tax Rate. As
previously
 noted, this adjustment results in non-GAAP measures that only reflect
part, but not all, of
 an accounting concept and thus results in tailored accounting measures.
Refer to
 Question 100.04 of the Division s Compliance & Disclosure
Interpretations on Non-
 GAAP Financial Measures and confirm that you will no longer include this
adjustment in
 the determination of these non-GAAP measures in future filings,
including earnings
 releases filed under Form 8-K
Item 8. Financial Statements and Supplementary Data
1. Basis of Presentation and Accounting Policies - Basis of Presentation, page
46

4. We note that certain prior-year amounts in the Consolidated Statement of
Operations
 have been reclassified to engineering and development to conform to the
current-year
 presentation. We further note that these amounts were previously
classified as cost of
 sales. Please disclose how you currently define cost of sales. In
addition, provide us with
 (i) your prior definition of cost of sales, (ii) a sufficiently detailed
discussion of the
 nature of the costs no longer identified as cost of sales and (ii) your
basis for concluding
 these costs should no longer be included in cost of sales.
Item 2.02 Form 8-K filed February 5, 2026
Exhibit 99.
Supplemental Information, page 5

5. Please expand your disclosures surrounding your non-GAAP measures,
return on
 invested capital and adjusted EBITDA, to present the most comparable
GAAP measures
 with equal or greater prominence. Refer Item 10(e)(1)(i)(A) of
Regulation S-K and
 Question 102.10 of the Division of Corporation Finance s Compliance &
Disclosure
 Interpretations on Non-GAAP Financial Measures.
Return on Invested Capital, page 17

6. Your Return on Invest Capital (ROIC) is computed using a non-GAAP
"return" measure
 in your numerator because you adjust net operating profit after tax for
purchase
 accounting depreciation and amortization and impairment. As previously
noted, the
 exclusion of purchase accounting depreciation and amortization results
in a non-GAAP
 measure that only reflects part, but not all, of an accounting concept
and thus results in a
 tailored accounting measure. Confirm that you will no longer exclude
purchase
 accounting depreciation and amortization in your calculation of ROIC. In
addition, if you
 continue to exclude the impairment adjustment from your calculation of
ROIC, please
 March 18, 2026
Page 3

 relabel your measure to highlight you have adjusted the commonly
calculated ROIC and
 revise to present the most directly comparable measure as commonly
calculated using
 GAAP amounts. Refer to Item 10(e)(1)(ii)(e) of Regulation S-K and
Question 100.05 of
 our Compliance and Disclosure Interpretations on Non-GAAP Financial
Measures
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff. Please contact Al Pavot at 202-551-3738 or Jeanne Baker at
202-551-3691 if
you have any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
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