SecProbe.io

June 25, 2014

Via E -mail
Mark S. Peek
Chief Financial Officer
Workday, Inc.
6230 Stoneridge Mall Road
Pleasanton, California 94588

Re: Workday, Inc.
 Form 10-K for the Fiscal Year Ended January 31, 2014
Filed March 31, 2014
File No. 001 -35680

Dear Peek :

We have reviewed your filing s and have the 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 advising us when  you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comment s, we may have  additional comments.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Gener al

1. We note that in your earnings calls you discuss the weighted average duration of new
contracts signed in the quarter.  Please tell us what consideration was given to disclosing
this metric in MD&A.  Also, tell us whether the weighted average duration o f new
contracts signed  is a key performance indicator for your business.  Refer to Section
III.B.1 of SEC Release 33 -8350.

Mark S. Peek
Workday, Inc.
June 25, 2014
Page 2

 Contractual Obligations, page 41

2. We note from disclosure on page 73 that you had $77 million of unrecognized tax
benefits as of Jan uary 31, 2014, which represents a significant increase over the prior
year.  Please tell us what consideration was given to disclosing liabilities relating to such
benefits in the table of contractual obligations or in a note thereto.   R efer to
Item 303(a )(5) of Regulation S -K and Section C of SEC Release 33 -9144.

Item 8. Consolidated Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements

Note 2. Summary of Significant Accounting Policies

Revenue Recognition

Professional Services Revenues, page 55

3. We note the change in your revenue recognition policy disclosure for professional
services from a milestone and customer acceptance method , as previously disclosed, to a
proportional performance method.  Please clarify whether there was a change in your
recognition method and if so, tell us the reason for the change in method and when the
change was effected.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 d isclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to d isclosure 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 fed eral securities laws of the United States.

Mark S. Peek
Workday, Inc.
June 25, 2014
Page 3

 You may contact , David Edgar, Staff Accountant , at (202) 551 -3459  if you have
questions regarding comments on the financial statements and re lated matters.  Please contact me
at (202) 551 -3406  with any other questions.

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief