TEXT-EXTRACT 2 filename2.txt April 25, 2019 John Murphy Chief Financial Officer Adobe Inc. 345 Park Avenue San Jose, California 95110-2704 Re: Adobe Inc. Form 10-K for the Fiscal Year Ended November 30, 2018 Filed January 25, 2019 Form 10-Q for the Quarterly Period Ended March 1, 2019 Filed March 27, 2019 File No. 000-15175 Dear Mr. Murphy: We have limited our review of your filing 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 March 1, 2019 Note 1. Basis of Presentation and Summary of Significant Accounting Policies Revenue Recognition, page 10 1. Please provide us with a comprehensive analysis of how you determined that the Creative Cloud and Document Cloud on-premise software and the related cloud functionality are highly integrated and interrelated and are therefore accounted for as a single performance obligation. Refer to 606-10-25-21. Also, tell us whether the Creative Cloud or the Document Cloud software licenses are sold without the cloud-enabled service and if so, tell us the amount of revenue generated from those license-only sales for each period presented. John Murphy Adobe Inc. April 25, 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 Eiko Yaoita Pyles, Staff Accountant at 202-551-3587 or Christine Dietz, Assistant Chief Accountant at 202-551-3408 with any questions. Sincerely, FirstName LastNameJohn Murphy Division of Corporation Finance Comapany NameAdobe Inc. Office of Information Technologies April 25, 2019 Page 2 and Services FirstName LastName