December 20, 2018

Andrew Anagnost
Chief Executive Officer
Autodesk, Inc.
111 McInnis Parkway
San Rafael, California 94903

       Re: Autodesk, Inc.
           Form 10-K for the Fiscal Year Ended January 31, 2018
           Filed March 22, 2018
           Form 10-Q for the Quarterly Period Ended April 30, 2018
           Filed June 8, 2018
           File No. 000-14338

Dear Mr. Anagnost:

        We have reviewed your November 6, 2018 response to our comment letter
and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.

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

      After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
October 23, 2018 letter.

Form 10-Q for the Quarterly Period Ended April 30, 2018

Note 3. Revenue Recognition, page 10

1.    We note your response to prior comment 1. With a specific focus on your
AutoCAD and
      AutoCAD LT product subscriptions (collectively "AutoCAD"), please tell us
how you
      concluded that the promise to transfer the AutoCAD desktop application is
not separately
      identifiable from the promise to transfer AutoCAD cloud services in
accordance with
      ASC 606-10-25-21.Within your response please discuss, at a minimum:

          The specific functionalities that reside within the cloud services of
AutoCAD and are
          incremental to the AutoCAD desktop application, with a focus on the
specific
 Andrew Anagnost
Autodesk, Inc.
December 20, 2018
Page 2
             functionalities that were significant to the Company's conclusion
that the AutoCAD
             desktop application is not distinct from the AutoCAD cloud
services. Additionally,
             please describe the extent to which these specific AutoCAD cloud
service
             functionalities are incremental to similar functionalities, if
any, in the AutoCAD
             desktop application.

             How the specific AutoCAD cloud service functionalities interact
with and/or are
             integrated with the AutoCAD desktop application.

             How you determined that the nature of the promise, in the context
of the contract, is to
             transfer the combined item to which the AutoCAD desktop
application and the
             AutoCAD cloud services are inputs (for example, how each of the
AutoCAD desktop
             application and the AutoCAD cloud services significantly affects
the other's utility to
             the customer and therefore the customer's ability to derive its
intended benefit from
             the contract depends on the Company transferring both the AutoCAD
desktop
             application and the AutoCAD cloud services). Consider whether one
or more
             examples would be helpful to illustrate this point.
       You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407
or Christine
Dietz, Assistant Chief Accountant, at (202) 551-3408 with any questions.



                                                               Sincerely,
FirstName LastNameAndrew Anagnost
                                                               Division of
Corporation Finance
Comapany NameAutodesk, Inc.
                                                               Office of
Information Technologies
December 20, 2018 Page 2                                       and Services
FirstName LastName