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 Document 1201 S. Second St. Milwaukee, WI 53204 USA April 13, 2026 Al Pavot Jeanne Baker Division of Corporation Finance United States Securities and Exchange Commission Washington, DC 20549 Re: ROCKWELL AUTOMATION, INC. Form 10-K filed November 12, 2025, File No. 001-12383 Dear Mr. Pavot and Ms. Baker: Rockwell Automation, Inc. (the “Company”, “Rockwell”, “we” or “us”), responds below to the comments of the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended September 30, 2025 (the “Form 10-K”) filed on November 12, 2025 (File No. 001-12383), contained in your comment letter dated March 18, 2026 (the “Comment Letter”). For convenience of reference, each Staff comment contained in the Comment Letter is reprinted below in italics, numbered to correspond with the paragraph number assigned in the Comment Letter, and each Staff comment is followed by the corresponding response of the Company. 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. 1 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 continue to include this measure as appropriately revised, the reconciliation should start with net income, the most directly comparable GAAP measure. Response See our response to address the Staff’s comments under #2 and #3. 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. Response The Company respectfully acknowledges the Staff’s comment and confirms that it will update its presentation of total segment operating earnings and total segment operating margin to include corporate and other costs and be reported as enterprise operating profit and enterprise operating margin. These changes will be made prospectively, including recast of all comparable periods presented, beginning with the Form 10-Q and Form 8-K earnings release for the period ending March 31, 2026. As noted below in footnote (3) to our illustrative Summary of Results of Operations, we disclose income before income taxes and pre-tax margin as the closest GAAP measures to enterprise operating profit and enterprise operating margin as we do not present a GAAP measure of operating profit or operating margin. The Company respectfully acknowledges the Staff’s comment in #1 related to purchase accounting depreciation and amortization. Reference is made to our response under #3 in support of exclusion of amortization of acquisition-related intangible assets and impairments from our presentation of enterprise operating profit and enterprise operating margin. Set forth below is an illustrative example of how we intend to present our “Summary of Results of Operations” in future filings (Item 7 of Form 10-K and Item 2 of Form 10-Q): 2   Year Ended September 30,   2025 2024 2023 Sales       Intelligent Devices (a) $ 3,756  $ 3,804  $ 4,098  Software & Control (b) 2,383  2,187  2,886  Lifecycle Services (c) 2,203  2,273  2,074  Total sales (d) $ 8,342  $ 8,264  $ 9,058  Segment operating earnings (1)       Intelligent Devices (e) $ 676  $ 700  $ 828  Software & Control (f) 708  530  953  Lifecycle Services (g) 319  365  148  *Corporate and other (2) (125) (114) (110) *Enterprise operating profit (3) (h) 1,578  1,481  1,819  *Amortization of acquisition-related intangible assets (4) (141) (144) (106) *Impairment (224) —  (158) Non-operating pension and postretirement benefit (cost) credit (1) 20  (83) Net legacy asbestos and environmental charges (2) (154) (21) (18) Change in fair value of investments (3) —  279  Restructuring charges 5  (97) —  Interest expense, net (143) (139) (125) Income before income taxes (i) 917  1,100  1,608  Income tax provision (168) (152) (330) Net income 749  948  1,278  Net loss attributable to noncontrolling interests (120) (5) (109) Net income attributable to Rockwell Automation $ 869  $ 953  $ 1,387        Diluted EPS $ 7.67  $ 8.28  $ 11.95  Adjusted EPS (5) $ 10.53  $ 9.85  $ 12.25  Diluted weighted average outstanding shares 113.1  114.5  115.6  Pre-tax margin (i/d) 11.0  % 13.3  % 17.8  % Intelligent Devices segment operating margin (e/a) 18.0  % 18.4  % 20.2  % Software & Control segment operating margin (f/b) 29.7  % 24.2  % 33.0  % Lifecycle Services segment operating margin (g/c) 14.5  % 16.1  % 7.1  % *Enterprise operating margin (3) (h/d) 18.9  % 17.9  % 20.1  % (1) See Note 20 in the Consolidated Financial Statements for the definition of segment operating earnings. (2) Legacy asbestos and environmental charges were previously included in Corporate and other. All periods have been recast to conform with current year presentation. 3 *(3) Enterprise operating profit and enterprise operating margin are non-GAAP financial measures. We exclude from income before income taxes and pre-tax margin amortization of acquisition-related intangible assets, impairment, non-operating pension and postretirement benefit (cost) credit, net legacy asbestos and environmental charges, change in fair value of investments, restructuring charges aligned with enterprise-wide strategic initiatives, and interest expense, net because we do not consider these items to be directly related to the operating performance of our enterprise. We believe enterprise operating profit and enterprise operating margin are useful to investors as measures of operating performance. We use these measures to monitor and evaluate the profitability of our operating enterprise. Our measures of enterprise operating profit and enterprise operating margin may be different from measures used by other companies. *(4) Amortization of acquisition-related intangibles excludes amortization of internally developed and capitalized intangible assets. See the Supplemental Segment Information section for our presentation and reconciliation by segment. (5) Adjusted EPS is a non-GAAP earnings measure. See Adjusted Income, Adjusted EPS, and Adjusted Effective Tax Rate Reconciliation for more information on this non-GAAP measure. Please note * refers to the changes in our disclosure in response to the Staff’s comments. 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. Response The company respectfully acknowledges the Staff’s comment. Please note that the adjustment of purchase accounting depreciation and amortization relates to amortization of identifiable intangible assets recognized in conjunction with the purchase price allocation for acquisitions, including: software products, customer relationships, technology, and trademarks. We also have amortization related to intangible assets that are internally developed that is not included in the adjustment of purchase accounting depreciation and amortization. We report this as an operating expense as it is directly attributable to ongoing operations, consistent with our organic growth, and with how we internally evaluate the financial performance of the Company. The adjustment to earnings for amortization of acquired intangible assets comprises more than 90% of total amortization. Management and the Company’s Board of Directors consistently employ these non-GAAP measures to evaluate ongoing business operations, determine incentive compensation, make informed decisions regarding capital allocation, and project future performance. This adjustment is also useful to investors as we routinely receive inquiries regarding the comparability of operating results between periods, particularly after an acquisition because the unique facts and circumstances of an acquisition can generate variation in our operating results. Additionally, this adjustment provides investors with the information required to analyze comparability of the Company’s operating results to those of our competitors that grow organically and access to the same metrics used by management and the board of directors, thereby enhancing transparency and utility. We have observed that this adjustment is common across peer companies and industries and therefore comparable presentation of adjusted earnings is useful as we and our investors evaluate operational performance. 4 In response to the Staff’s comments, we will expand the disclosure in our annual and quarterly filings as follows: • rename purchase accounting depreciation and amortization as “Amortization of acquisition-related intangible assets”, • disclose impairments as a separate line item, and • include a footnote to the reconciliation tables for Adjusted Income, Adjusted EPS, and Adjusted Effective Tax Rate in Item 7 (Form 10-K) and Item 2 (Form 10-Q) to add a description for amortization of acquisition-related intangible assets as follows: The Company adjusts its non-GAAP results to exclude Amortization of acquisition-related intangible assets as such amounts are significantly impacted by the timing and/or size of acquisitions. Management believes that the adjustment of Amortization of acquisition-related intangible assets supplements the GAAP information with a measure that can be used to assess the comparability of operating performance between periods and as compared to industry peers. Although the Company excludes Amortization of acquisition-related intangible assets from its non-GAAP expenses, management believes that it is important for investors to understand that such intangible assets were recorded as part of an acquisition and contribute to revenue generation. Additionally, we will expand our disclosures in the annual and quarterly filings in the Supplemental Segment Information in Item 7 (Form 10-K) and Item 2 (Form 10-Q). Footnote (1) will include a quantification of amortization to provide investors with a reconciliation of total amortization in the period presented. Set forth below is an illustrative example of how we intend to present our “Supplemental Segment Information” in future filings: 5   Year Ended September 30,   2025 2024 2023 *Amortization of acquisition-related intangible assets (1)       Intelligent Devices $ 37  $ 38  $ 5  Software & Control 66  68  69  Lifecycle Services 38  38  32  *Impairment Intelligent Devices $ —  $ —  $ —  Software & Control —  —  —  Lifecycle Services 224  —  158  Non-operating pension and postretirement benefit (credit) cost Intelligent Devices $ (2) $ (7) $ 21  Software & Control (1) (7) 21  Lifecycle Services (2) (10) 28  Restructuring charges Intelligent Devices $ (2) $ 44  $ —  Software & Control (2) 33  —  Lifecycle Services (1) 20  —  (1) * Amortization of acquisition-related intangible assets does not include amortization for Intangibles internally developed, which is included in segment operating earnings. For the years ended September 30, 2025, 2024 and 2023, the amortization expense for internally developed intangible amortization was $11 million, $11 million and $10 million, respectively. Please note * refers to the changes in our disclosure in response to the Staff’s comments. We believe these additional disclosures would provide useful information to further enhance an investor's ability to evaluate the Company’s performance. 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 (iii) your basis for concluding these costs should no longer be included in cost of sales. Response (i) Definition of cost of sales (Current and Prior) Cost of sales has been consistently defined and reported across historical reporting periods. Cost of sales includes material, labor and overhead expenses directly attributable to (i) specific units of inventory produced, (ii) the delivery of specific services, or (iii) the fulfillment of current customer contracts related to producing goods sold or providing services that generate revenue. Prior to the change in presentation in the 6 fourth quarter of fiscal 2025, cost of sales also included research and development (R&D) and engineering costs within cost of sales which is disclosed in Note 1. (ii) Sufficiently detailed discussion of the nature of the costs no longer identified as cost of sales Engineering and Development (E&D) includes R&D costs consistent with the definition under ASC 730 and other engineering costs including routine enhancements or improvements to existing products, production lines, manufacturing processes and other ongoing operations. These costs are not directly related to revenue generating customer contracts that would be required to be classified in cost of sales. (iii) Basis for concluding these costs should no longer be included in cost of sales. A management decision was made in the fourth quarter of 2025 to change the basis of presentation to enhance transparency of engineering and development costs for investors, simplify gross margin reporting for internal performance management and align more closely with the comparable presentation used by peer companies. ASC 730 and Regulation S-X, Rule 5-03(b) do not present explicit guidance on where an entity is required to classify engineering and development costs that are not directly related to revenue generating customer contracts in the income statement. As noted above, the historical classification of R&D in cost of sales