October 17, 2019

Robert Eulau
Chief Financial Officer
Western Digital Corporation
5601 Great Oaks Parkway
San Jose, California 95119

       Re: Western Digital Corporation
           Form 10-K for the Fiscal Year Ended June 28, 2019
           Filed August 27, 2019
           File No. 001-08703

Dear Mr. Eulau:

       We have reviewed your October 7, 2019 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in our
September 16, 2019 letter.

Form 10-K for the Fiscal Year Ended June 28, 2019

Item 7. Management's Discussion and Analysis of Financial Conditions and
Results of
Operations, page 34

1.    You indicate in your response to prior comment 1 that measures such as
units sold and
      average selling prices may be indicators of or contributors to the
company's financial
      performance, however, you do not believe disclosure of these metrics
conveys material
      information that promotes an understanding of the company's operating
performance.
      However, we note that your results of operations discussion focuses on
the change in
      products sold and average selling prices and the impact of those changes
on revenue by
      end market. Given such emphasis, please further explain why you believe a
quantified
      discussion of such measures would not provide investors with a better
understanding of
      your operating results. Refer to Section III.B.1 of SEC Release 33-8350.
 Robert Eulau
Western Digital Corporation
October 17, 2019
Page 2
2.       You disclose that the decrease in Client Devices revenue was driven by
lower average
         selling prices per gigabyte for flash-based products and lower sales
of HDD products and
         flash-based mobile products. As another example, you indicate the
decrease in Client
         Solutions revenue was driven by lower average selling prices of
flash-based products and
         lower sales of retail HDD products. Where a material change in a line
item is attributed to
         two or more factors, including any offsetting factors, the
contribution of each identified
         factor should be described in quantified terms, if reasonably
practicable. Please revise
         your disclosures in future filings accordingly. Similar revisions
should be considered
         throughout your results of operations disclosures, such as in your
discussion of the change
         in research and development and selling, general and administrative
expenses. Refer to
         Item 303(a)(3)(ii) of Regulation S-K and Section III.D of SEC Release
No. 33-6835.
        You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or
Melissa
Kindelan, Senior Staff Accountant at 202-551-3564 if you have questions
regarding comments
on the financial statements and related matters.



FirstName LastNameRobert Eulau                                Sincerely,
Comapany NameWestern Digital Corporation
                                                              Division of
Corporation Finance
October 17, 2019 Page 2                                       Office of
Technology
FirstName LastName