March 25, 2020

Patrick Grismer
Executive Vice President and Chief Financial Officer
Starbucks Corporation
2401 Utah Avenue South
Seattle, Washington 98134

       Re: Starbucks Corporation
           Form 10-K for the Fiscal Year Ended September 29, 2019
           Filed November 15, 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-K for the Fiscal Year Ended September 29, 2019

Item 8. Financial Statements and Supplementary Data
Consolidated Statements of Earnings, page 44

1.    Please tell us whether all of the costs below are included in cost of
sales:
        labor and benefits costs related to store employees preparing
beverages, food and
           ground coffee,
        distribution costs for inventory sent to company-owned stores, and
        depreciation costs of store equipment used in preparing beverages, food
and ground
           coffee.
      If all of these costs are not included in cost of sales, please also tell
us how
      you determined that they were not required to be included or retitle this
line item to better
      reflect what it represents. Refer to ASC 330-10-30.
2.    Please present the material components of the store operating expenses
line item
      separately. Refer to Rule 5-03.3 of Regulation S-X.
 Patrick Grismer
Starbucks Corporation
March 25, 2020
Page 2
Note 1. Summary of Significant Accounting Policies, page 50

3.       Please tell us and disclose in an accounting policy footnote the
specific types of amounts
         included in cost of sales, store operating expenses and general and
administrative
         expenses.
Note 16. Segment Reporting, page 81

4.       Please disclose your revenues from China or tell us how you determined
that they were
         not material. Refer to ASC 280-10-50-41(a).
        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 Angela Lumley at 202-551-3398 or Rufus Decker at
202-551-3769 with
any questions.



FirstName LastNamePatrick Grismer                              Sincerely,
Comapany NameStarbucks Corporation
                                                               Division of
Corporation Finance
March 25, 2020 Page 2                                          Office of Trade
& Services
FirstName LastName