September 24, 2018

Sean Edgett
General Counsel
Twitter, Inc.
1355 Market Street, Suite 900
San Francisco, CA 94103

       Re: Twitter, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 23, 2018
           Form 10-Q for the Quarterly Period Ended June 30, 2018
           Filed July 30, 2018
           File No. 001-36164

Dear Mr. Edgett:

       We have limited our review of your filings to the financial statements
and related
disclosures 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-Q for the Quarterly Period Ended June 30, 2018

Note 1. Description of Business and Summary of Significant Accounting Policies
Revenue Recognition, page 12

1.    Please provide us the following information with regards to your data
licensing
      arrangements:

          Describe further those arrangements that contain multiple performance
obligations and
          tell us what additional services are provided that are not included
in arrangements with
          a single performance obligation.
 Sean Edgett
Twitter, Inc.
September 24, 2018
Page 2

          Tell us if you have concluded that these arrangements contain a
license of intellectual
          property or if they represent a service transferred to customers.
Refer to ASC 606-10-
          55-54 through 63.

          For arrangements that contain royalty based fees, tell us if you have
applied the royalty
          guidance for licenses in ASC 606-10-55-65 or if you have applied
guidance on
          variable consideration in ASC 606-10-32-40. Please specifically
address how you
          considered your escalating fee structure.

Note 12. Income Taxes, page 27

2.    We note based on information available at December 31, 2017, management
believed it
      was more-likely-than-not that the net Brazil deferred tax assets were not
fully realizable.
      Please provide us with a detailed analysis to support your subsequent
conclusion at June
      30, 2018 that realization of the net deferred tax assets related to your
Brazilian operations
      were more likely than not such that you released a $41.7 million tax
valuation allowance.
      Also, specifically address the facts and circumstances that led to
recording the valuation
      allowance initially and how they changed since year-end. Refer to ASC
740-10-30-5(e)
      and ASC 740-10-30-16 through 30-25.
3.    Please include a discussion of the realizability estimates for deferred
tax assets. Refer to
      ASC 740-10-50-21. Also, revise to disclose the specific circumstances
that led to such
      release and the circumstances that could reasonably cause you to adjust
your valuation in
      the future. Refer to Section III.B.3 of SEC Release 33-8350.
       In closing, 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.

      You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or
Kathleen Collins,
Accounting Branch Chief at (202) 551-3499 with any questions.



                                                             Sincerely,

FirstName LastNameSean Edgett                                Division of
Corporation Finance
                                                             Office of
Information Technologies
Comapany NameTwitter, Inc.
                                                             and Services
September 24, 2018 Page 2
cc:       Lisa Stimmell
FirstName LastName