United States securities and exchange commission logo





                              September 23, 2021

       Brian T. Olsavsky
       Chief Financial Officer
       Amazon.com, Inc.
       410 Terry Avenue North
       Seattle, WA 98109

                                                        Re: Amazon.com, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2020
                                                            Filed February 3,
2021
                                                            File No. 000-22513

       Dear Mr. Olsavsky:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for Fiscal Year Ended December 31, 2020 Filed February 3, 2021

       General

   1.                                                   We note your
disclosures in your CSR report expressing your commitment to utilize your
                                                        size and scale toward
climate and environmental innovations, and your statement that you
                                                        are committed to
building a sustainable business for your employees, customers and
                                                        communities. We also
note that you provided more expansive disclosure in your CSR
                                                        report than you
provided in your SEC filings. Please advise us what consideration you
                                                        gave to providing the
same type of climate-related disclosure in your SEC filings as you
                                                        provided in your CSR
report.
       Management's Discussion and Analysis, page 19

   2.                                                   We note the disclosure
in your proxy statement and your CSR report that you are taking
                                                        meaningful steps in
your journey to be net-zero carbon by 2040 through significant
                                                        investments in
renewable energy and sustainability initiatives. If material, please quantify
 Brian T. Olsavsky
Amazon.com, Inc.
September 23, 2021
Page 2
      capital expenditures and compliance costs for these climate-related
initiatives.
3.    To the extent material, discuss the indirect consequences of
climate-related regulation or
      business trends, such as the following:
          decreased demand for goods or services that produce significant
greenhouse gas
          emissions or are related to carbon-based energy sources;
          increased demand for goods that result in lower emissions than
competing products;
          increased competition to develop innovative new products that result
in lower
          emissions; and
          any anticipated reputational risks resulting from operations or
products that produce
          material greenhouse gas emissions.
4.    Disclose the material effects of transition risks related to climate
change that may affect
      your business, financial condition, and results of operations, such as
policy and regulatory
      changes that could impose operational and compliance burdens, market
trends that may
      alter business opportunities, credit risks, or technological changes.
        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 Cara Wirth at (202) 551-7127 or Lilyanna Peyser at (202)
551-3222 with
any questions.



                                                            Sincerely,
FirstName LastNameBrian T. Olsavsky
                                                            Division of
Corporation Finance
Comapany NameAmazon.com, Inc.
                                                            Office of Trade &
Services
September 23, 2021 Page 2
cc:       Mark Hoffman
FirstName LastName