October 23, 2018

Andrew Anagnost
Chief Executive Officer
Autodesk, Inc.
111 McInnis Parkway
San Rafael, California 94903

       Re: Autodesk, Inc.
           Form 10-K for the Fiscal Year Ended January 31, 2018
           Filed March 22, 2018
           Form 10-Q for the Quarterly Period Ended April 30, 2018
           Filed June 8, 2018
           File No. 000-14338

Dear Mr. Anagnost:

       We have reviewed your August 23, 2018 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
August 3, 2018 letter.

Form 10-Q for the Quarterly Period Ended April 30, 2018

Note 3. Revenue Recognition, page 10

1.    We note your response to prior comment 5. Please provide a more specific
and
      comprehensive discussion regarding how your desktop software and related
cloud
      functionality create a collaborative workforce. Provide us with more
details regarding
      your statement that a collaborative design workforce is created.
 Andrew Anagnost
Autodesk, Inc.
October 23, 2018
Page 2

       You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407 or
Christine
Dietz, Assistant Chief Accountant, at 202-551-3408 with any questions.



                                                        Sincerely,
FirstName LastNameAndrew Anagnost
                                                        Division of Corporation
Finance
Comapany NameAutodesk, Inc.
                                                        Office of Information
Technologies
October 23, 2018 Page 2                                 and Services
FirstName LastName