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Writer’s Direct Number: (425) 313-2060

Fax: (425) 313-6800

May 15, 2025

BY EDGAR

Patrick Kuhn and Lyn Shenk

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549

Re: Costco Wholesale Corporation -- Form 10-K for the Fiscal Year Ended September 1, 2024, Response dated April 21, 2025 -- File No. 000-20355

Dear Mr. Kuhn and Mr. Shenk:

In response to your letter of May 12, 2025 (the “Letter”), please see the discussion below, which corresponds to the paragraph in your 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.

Response:

We will revise our disclosures in our next Annual Report on Form 10-K to clarify the rationale behind the methodology of our renewal rate calculation and active memberships.

Please contact me if you have any questions or further comments.

Sincerely,

    

COSTCO WHOLESALE CORPORATION

/s/    GARY MILLERCHIP
Gary Millerchip
Executive Vice President and Chief Financial Officer