SecProbe.io

January 12, 2012
 Via E-Mail

Stephen J. Luczo, Chief Executive Officer  Seagate Technology plc  38/39 Fitzwilliam Square Dublin 2, Ireland

Re: Seagate Technology plc
  Form 10-K for the Fiscal Year Ended July 1, 2011   Filed August 17, 2011   Definitive Proxy Statem ent Filed on Schedule 14A
  Filed September 26, 2011
File No. 001-31560

Dear Mr. Luczo:

We have reviewed your filings and have th e following comment.  In our comment, we
may ask you to provide us with informati on so we may better understand your disclosure.
 Please respond to this letter within te n business days by amending your filings, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comment applies 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 f ilings and the information you provide in
response to our comment, we ma y have additional comments.
 Form 10-K for the Fiscal Year Ended July 1, 2011

 Part III Information Incorporation By Refe rence in Schedule 14A Filed on September 26, 2011

 Compensation of Named Executive Officers, page 50

 1. In your response letter, please discuss the f actors that led your compensation committee
to award performance-vesting shares and stock options in the amount of $1,898,555 and
$3,951,827, respectively, to Mr. Albert A. Pime ntal in fiscal year 2011.  See Item
402(b)(2) of Regulation S-K.  Al so, please confirm that in fu ture filings, as applicable,
you will provide similar disclosure regarding the specific factors considered in awarding
compensation to each of your named executive officers.

Stephen J. Luczo
Seagate Technology plc  January 12, 2012 Page 2

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filings to be certain that the filings incl ude the information the Secu rities 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 comment, please provide 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.

Please contact Edwin Kim, Staff Attorney, at (202) 551-3297 or me at (202) 551-3456
with any questions.  If you require further a ssistance, you may contact Barbara C. Jacobs,
Assistant Director, at  (202) 551-3735.

Sincerely,
         /s/ Matthew Crispino          M a t t h e w  C r i s p i n o
Attorney-Advisor
cc:   Via E-Mail

  Kenneth M. Massaroni, Esq,   Patrick O'Malley, CFO