May 12, 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
           Response dated April 21, 2025
           File No. 000-20355
Dear Gary Millerchip:

       We have reviewed your April 21, 2025 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in
our March
19, 2025 letter.

Form 10-K for the Fiscal Year Ended September 1, 2024
Business
Memberships, page 5

1.     We note your response to prior comment 1 and 3. Please clarify your
disclosure so
       users have better understanding of your rational behind the methodology
of your
       renewal rate calculation and active memberships.
 May 12, 2025
Page 2

       Please contact Patrick Kuhn at 202-551-3308 or Lyn Shenk at 202-551-3380
if you
have questions regarding comments on the financial statements and related
matters.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Trade &
Services