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                             February 28, 2024

       Robert Park
       Chief Financial Officer
       Dolby Laboratories, Inc.
       1275 Market Street
       San Francisco, CA 94103

                                                        Re: Dolby Laboratories,
Inc.
                                                            Form 10-K for the
year ended September 29, 2023
                                                            Filed November 17,
2023
                                                            Form 8-K
                                                            Filed November 16,
2023
                                                            File No. 001-32431

       Dear Robert Park:

                                                        We have reviewed your
filing and have the following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

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

       Form 10-K for the year ended September 29, 2023

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 38

   1.                                                   We note your discussion
and analysis of the changes in your income tax on page 41.
                                                        Based on your effective
tax rate reconciliation within Note 12, it appears there are other
                                                        material factors
impacting your income tax benefit/(expense) that should be included in
                                                        MD&A so that readers
can fully understand the variances and assess the continuing
                                                        impact. For example, it
appears that the differences on rates of foreign operations changed
                                                        from a 4.5% decrease to
your effective tax rate in 2022 to a 1.9% decrease to
                                                        the effective tax rate
in 2023 while the proportion of income before income taxes for your
                                                        international
operations remained fairly consistent at approximately 84% of total income
                                                        before operations for
2022 and 82% in 2023. To the extent material factors in your foreign
                                                        operations including
changes in your jurisdictional mix of income may be impacting
                                                        your effective tax
rate, please explain the changes and factors including whether you may
 Robert Park
FirstName LastNameRobert    Park
Dolby Laboratories, Inc.
Comapany28,
February   NameDolby
            2024        Laboratories, Inc.
February
Page 2 28, 2024 Page 2
FirstName LastName
         expect these changes to continue. Given the materiality of your
foreign operations and
         impact on your effective tax rate, please also tell us your
consideration of including a
         discussion of the primary taxing jurisdictions where your foreign
earnings are derived, the
         location of tax holidays and the relevant statutory rates in those
jurisdictions in order for
         readers to better understand the material impacts such factors have on
your effective tax
         rate. Please refer to Item 303 of Regulation S-K and Sections
501.12.b.3 and 501.12.b.4.
         of the Financial Reporting Codification for guidance.
Note 13. Restructuring, page 82

2.       In future filings, please also expand your disclosures here or within
MD&A to disclose the
         expected effects on future earnings and cash flows resulting from each
of
         your restructuring plans along with the initial period in which those
effects are expected to
         be realized. In that regard, quantify the impact the restructuring
activities had on your
         operating income (i.e., the amount by which expenses decreased) and
cash flows,
         including whether the actual results were in line with management   s
expectations when
         the restructuring activities were initiated. If the anticipated
savings were not achieved as
         expected or are achieved in periods other than as expected, please
disclose as such, the
         reasons for the differences and the likely effects on future operating
results and liquidity.
         Please refer to SAB Topic 5:P.4 for guidance
Form 8-K filed November 16, 2023

General

3.       Please elaborate upon your disclosure related to the adjustment for
amortization of
         acquisition-related intangibles to arrive at Non-GAAP Net Income.
Specifically,
             explain the nature of intangible asset amortization expense that
has been included in
             the adjustment, as it appears that only a portion of amortization
expense recognized
             for the period has been included, and
             provide more robust disclosure explaining why management believes
this adjustment,
             which excludes some, but not all, amortization expense, results in
a non-GAAP
             measure that is useful to investors, as well as any other
additional purposes for which
             management uses this measure.
4.       Given that the GAAP to non-GAAP reconciliation starts with net income
attributable to
         Dolby Laboratories, Inc. adjusted for income/loss attributable to
noncontrolling interest,
         please revise the label of your non-GAAP measure "Non-GAAP net income"
to reflect the
         fact that it is non-GAAP net income attributable to Dolby
Laboratories, Inc.
        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 Ameen Hamady at 202-551-3891 or Kristi Marrone at
202-551-3429 if
 Robert Park
Dolby Laboratories, Inc.
February 28, 2024
Page 3

you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameRobert Park                              Sincerely,
Comapany NameDolby Laboratories, Inc.
                                                           Division of
Corporation Finance
February 28, 2024 Page 3                                   Office of Real
Estate & Construction
FirstName LastName