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                            June 15, 2022

       Parag Agrawal
       Chief Executive Officer
       Twitter, Inc.
       1355 Market Street, Suite 900
       San Francisco, California 94103

                                                        Re: Twitter, Inc.
                                                            Annual Report on
Form 10-K for the fiscal year ended December 31, 2021
                                                            Filed February 16,
2022
                                                            Quarterly Report on
Form 10-Q for the quarter ended March 31, 2022
                                                            Filed May 2, 2022
                                                            File No. 001-36164

       Dear Mr. Agrawal:

              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.

       Annual Report on Form 10-K filed February 16, 2022

       Risk Factors
       We rely on assumptions . . . , page 24

   1.                                                   We note your estimate
that the average number of false or spam accounts during fiscal
                                                        2021 continues to
represent fewer than 5% of mDAU. To the extent material, please
                                                        disclose the
methodology used in calculating these figures and the underlying judgements
                                                        and assumptions used by
management.
 Parag Agrawal
FirstName
Twitter, Inc.LastNameParag Agrawal
Comapany
June        NameTwitter, Inc.
     15, 2022
June 15,
Page 2 2022 Page 2
FirstName LastName
Quarterly Report on Form 10-Q for the period ended March 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of
Operations
mDAU Recast, page 34

2.       You disclosed that an error was made in March 2019 which resulted in
an overstatement
         of mDAU from the first quarter of 2019 through the fourth quarter of
2021. Please
         discuss how the error was discovered, when and by whom. Given that the
error persisted
         for three years, please tell us how you concluded there was not a
material weakness in
         your internal control over financial reporting and that your
disclosure controls and
         procedures were effective as of March 31, 2022.
        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 Claire DeLabar, Senior Staff Accountant, at (202)
551-3349 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Austin
Pattan, Staff
Attorney, at (202) 551-6756 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:      Katharine Martin