SecProbe.io

February 17, 2011
 Stephen J. Luczo Chief Executive Officer Seagate Technology Public Limited Company Arthur Cox Building Earlsfort Terrace Dublin 2, Ireland
Re:  Seagate Technology Public Limited Company
Form 10-Q for the quarterly period ended December 31, 2010
Filed February 3, 2011 Form 10-K for the fiscal year ended July 2, 2010 Filed August 20, 2010 File No. 001-31560

Dear Mr. Luczo:
 We have reviewed your filings and have th e following comments.  Please note that we
have limited our review to only your financial statements and related disclosures.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
 Form 10-Q for the quarterly period ended December 31, 2010

Consolidated Financial Statements
Note 12.  Legal, Environmental and Other Contingencies
Convolve, Inc. (“Convolve”) and Massachusetts  Institute of Technol ogy (“MIT”) v. Seagate
Technology LLC, et al., page 27
1. You disclose that this complaint seeks in junctive relief, $800 million in compensatory
damages and “unspecified punitive damages,  including willful infringement.”  Please

 Stephen J. Luczo Seagate Technology Public Limited Company February 17, 2011 Page 2
 revise to disclose the range of possible lo sses that could result from possible punitive
damages, including willful infringement.
Form 10-K for the fiscal year ended July 2, 2010

 Consolidated Financial Statements

 Note 5.  Debt and Convertible Notes, page 85

2. Please tell us your basis for not providing condensed consolidating financial information
pursuant to Rule 3-10 of Regulation S-X for each  security described in Note 5 that was
outstanding at the balance sheet date, other than those for which you disclose that the
security was issued pursuant to a privat e placement exemption and not subsequently
registered.  We note that Section III.C.1 of  Release 34-43124 clarifies that the parent
company periodic reports must include the modified financial information permitted by paragraphs (b) through (f) of Rule 3-10 of Regulation S-X for as long as the subject
securities are outstanding.  Applied to your facts and circumstances, it appears that SX 3-
10 disclosure may have been required for certain securities no twithstanding that the
securities were fully paid and extinguished subsequent to the ba lance sheet date, but
before filing your Form 10-K.  Similarly, it appears that SX 3-10 disclosure may have
been required for certain securities notwithst anding the filing within the fiscal year of a
Form 15 related to those securities.
Note 13.  Legal, Environmental and Other Contingencies, page 113

3. We note your disclosures beginning on page 113 regarding the various litigation matters
to which the Company is exposed.  Please indi cate why you believe that your disclosure
properly discloses your determination of the range of the likelihood of an unfavorable
outcome as defined in FASB ASC 450-20-25-1 (i.e., probable, reasonably possible, and
remote).  We also note that  you have not disclosed either:
(i) the possible loss or range of loss; or
(ii) a statement that an estimate of the loss cannot be made.
If you believe that the likelihood of an unfa vorable outcome is remote, please explain
how your disclosure properly distinguishe s this outcome from the possible outcomes
within the range.  Further,  please clarify how your disc losures comply with the
requirements in paragraphs 3 through 5 of  FASB ASC 450-20-50 and SAB Topic 5Y for
those contingencies that you have determined to  be probable or reason ably possible.  In
this regard for each material contingency, you should disclose an estimate of the possible
loss or range of loss or a statement that such estimate cannot be made.

 Stephen J. Luczo Seagate Technology Public Limited Company February 17, 2011 Page 3

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

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

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Morgan Y oungwood, Staff Accountant, at  (202) 551-3479 if you have
any questions regarding comments on the financ ial statements and related matters.  Please
address questions regarding all other comments to  Philip Rothenberg, Staff Attorney, at (202)
551-3466 or Barbara Jacobs, Assistant Director , at (202) 551-3730.  If you need further
assistance, you may cont act me at (202) 551-3730.

       S i n c e r e l y ,         /s/ Stephen Krikorian
              S t e p h e n  K r i k o r i a n          A c c o u n t i n g  B r a n c h  C h i e f