March 19, 2025

Gary Millerchip
Executive Vice President and Chief Financial Officer
Costco Wholesale Corporation
999 Lake Drive
Issaquah, WA 98027

       Re: Costco Wholesale Corporation
           Form 10-K for Fiscal Year Ended September 1, 2024
           File No. 000-20355
Dear Gary Millerchip:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended September 1, 2024
Business
Membership, page 6

1.     You disclose your membership renewal rate is a trailing calculation that
captures
       renewals during the period seven to eighteen months prior to the
reporting date. Please
       further describe your renewal rate calculation to us, including why you
use this time
       period.
2.     Please revise to clarify whether the membership figures in the table are
as of a point in
       time or for a period of time.
3.     You state membership counts include active memberships as well as
memberships
       that have not renewed within the 12 months prior to the reporting date.
Please tell us
       your basis for including memberships that have not renewed within the 12
months
       prior to the reporting date.
 March 19, 2025
Page 2

Management's Discussion and Analysis of Financial Conditions and Results of
Operations
Results of Operations, page 25

4.     Please revise to quantify factors to which changes are attributed. For
example, you
       state the increase in net sales was attributable to an increase in
comparable sales and
       the opening of new warehouses, partially offset by one less week of
sales. As another
       example, you cite wage increases as impacting SG&A expenses. Please also
revise to
       quantify impacts of changes in price and volume on revenue. Refer to
Item 303(b)(2)
       of Regulation S-K.
Notes to Consolidated Financial Statements
Note 1 - Summary of Significant Accounting Policies
Revenue Recognition, page 46

5.     We note your disclosure that you derive a portion of your revenue from
Citibank,
       including a royalty on purchases made on the co-branded card outside of
Costco.
       Please tell us the amounts of revenue you recognized from Citibank,
including such
       royalties, in each of the last three fiscal years and latest interim
period. Please also tell
       us the nature and extent of any direct costs associated with this
revenue. Finally,
       please tell us how you categorize this revenue in your table of
disaggregated revenue
       in Note 11 on page 62.
        In closing, 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.

       Please contact Patrick Kuhn at 202-551-3308 or Lyn Shenk at 202-551-3380
with any
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services