October 18, 2019

Larry Page
Chief Executive Officer
Alphabet Inc.
1600 Ampitheatre Parkway
Mountain View, CA 94043

       Re: Alphabet Inc.
           Form 10-Q for the Quarterly Period Ended June 30, 2019
           Filed July 26, 2019
           File No. 001-37580

Dear Mr. Page:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

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

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

Form 10-Q for the Quarterly Period Ended June 30, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Revenues, page 33

1.    Please revise MD&A to provide a discussion and analysis that provides
quantitative and
      qualitative information about different products or revenue components
(i.e., property and
      platform) material to an understanding of your results of operations as
required by Item
      303 of Regulation S-K. Specifically, in this regard, we note that
YouTube, mobile search
      and desktop search have experienced different growth and monetization
rates and enjoy
      different margins. As such, they represent significant subdivisions or
components of
      Google properties revenues that should be discussed separately to allow
investors to view
      the company through the eyes of management. We also note that certain
metrics appear to
      be significantly impacted by YouTube.
 Larry Page
Alphabet Inc.
October 18, 2019
Page 2



       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 Morgan Youngwood, Staff Accountant, at 202-551-3479 or
Stephen
Krikorian, Accounting Branch Chief, at 202-551-3488 with any questions.



FirstName LastNameLarry Page                              Sincerely,
Comapany NameAlphabet Inc.
                                                          Division of
Corporation Finance
October 18, 2019 Page 2                                   Office of Technology
FirstName LastName