September 28, 2017

Ms. Cecilia Blye

Chief, Office of Global Security Risk

United States Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-3561

RE:    SEC Comment Letter dated September 21, 2017

The Walt Disney Company

Form 10-K for the fiscal year ended October 1, 2016

Filed November 23, 2016

File No. 1-11605

Dear Ms. Blye:

The Walt Disney Company (the “Company”) hereby advises the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that the Company has received the Staff’s letter dated September 21, 2017 (the “Comment Letter”), regarding the Commission’s review of the Company's Annual Report on Form 10-K for the fiscal year ended October 1, 2016. The Comment Letter requests that the Company respond within ten (10) business days from the date thereof, or inform the Staff of when the Company would provide a response.

During a telephonic conversation with Pradip Bhaumik, Special Counsel, on September 26, 2017, I advised him that the Company is working to respond to the Comment Letter and will require additional time due to time constraints associated with its fiscal year end and the availability of key personnel responsible for the preparation, review and approval of our response. Accordingly, the Company respectfully requested an extension until October 23, 2017, and appreciate Mr. Bhaumik’s agreement to this date.

Should you have any further questions, please do not hesitate to call me at (818) 560-4645.

Sincerely,

/s/ Alicia Schwarz

Principal Counsel

Corporate Legal

cc:    Alan Braverman, Senior Executive Vice President, General Counsel and Secretary

Christine M. McCarthy, Senior Executive Vice President and Chief Financial Officer

Brent A. Woodford, Executive Vice President, Controllership, Financial Planning and Tax

Roger Patterson, Associate General Counsel and Assistant Secretary