July 8, 2019

Patrick J. Grismer
Chief Financial Officer
STARBUCKS CORP
2401 Utah Avenue South
Seattle, Washington 98134

       Re: STARBUCKS CORP
           Form 10-Q for the Quarter Ended March 31, 2019
           Filed April 30, 2019
           File No. 000-20322

Dear Mr. Grismer:

       We have reviewed your filing 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 Quarter Ended March 31, 2019

Item 1. Financial Statements (unaudited)
Notes to the Condensed Consolidated Financial Statements
Note 2. Revenue Recognition, page 11

1.    We note your response to our prior comment number 3 however our comment
was not
      intended to be specific only to license revenues. As previously
requested, please disclose
      revenue recognized during the reporting period that was included in
deferred revenue at
      the beginning of the period. We note from your footnote that beginning
deferred revenue
      balance for 2019 was $906.6 million relating to your stored value card
and loyalty
      program. Please disclose the related amount recognized during the period
as well as any
      amortization of deferred revenue related to the Nestle royalty prepayment
that
      was included in the beginning 2019 balance. Refer to ASC 606-10-50-8.
2.    We note your response to comment 5 however our comment was not intended
to
      be specific to license revenues. In this regard, please revise your
revenue footnote to
 Patrick J. Grismer
STARBUCKS CORP
July 8, 2019
Page 2
         include the disclosures required by ASC 606-10-65-1(i), including the
related amounts of
         the income statement line items affected in the current reporting
period by the application
         of the new revenue standard such as the accounting and
reclassification of breakage
         income.
3.       We note your response to comment 6. Please revise your disclosure to
include your
         explanation of why recognition of the upfont payment of $7 billion on
a straight-line basis
         over the economic life of the arrangement provides a faithful
depiction of the transfer of
         goods or services pursuant to ASC 606-10-50-18.
        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 Aamira Chaudhry at 202-551-3389 or Jean Yu at
202-551-3305 if you
have questions regarding comments on the financial statements and related
matters.



FirstName LastNamePatrick J. Grismer                           Sincerely,
Comapany NameSTARBUCKS CORP
                                                               Division of
Corporation Finance
July 8, 2019 Page 2                                            Office of
Transportation and Leisure
FirstName LastName