Amazon.com, Inc.

410 Terry Avenue North

Seattle, WA 98109-5210

(206) 266-1000

May 4, 2018

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attention: Mara Ransom

Re: Amazon.com, Inc.

Registration Statement on Form S-4 (File No. 333-224475)

Dear Ms. Ransom:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the registrant Amazon.com, Inc. (the “Company”), respectfully requests the acceleration of the effectiveness of the above-referenced Registration Statement (the “Registration Statement”), so as to become effective at 4:00 p.m. Eastern time on Monday, May 7, 2018 or as soon as possible thereafter.

Please do not hesitate to contact Andrew L. Fabens of Gibson, Dunn & Crutcher LLP at (212) 351-4034 with any questions or comments with respect to this letter.

Sincerely,
AMAZON.COM, INC.
By:	/s/ Kurt H. Zumwalt
Name:	Kurt H. Zumwalt
Title:	Vice President and Treasurer

cc:    Andrew L. Fabens, Esq., Gibson, Dunn & Crutcher LLP