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