ADBEAdobe Inc.

Please expand your discussion of the reasons you believe that your leadership structure is appropriate, addressing your specific characteristics or circumstances. In your discussion, please also address how the experience of the Lead Director is brought to bear in connection with your board’s role in risk oversight.

Adobe Inc. confirms receipt of the letter dated September 7, 2022, from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission relating to the above referenced Definitive Proxy Statement on Schedule 14A. In response to the Staff’s letter, we confirm that we will enhance, where appropriate, our future proxy disclosures in accordance with the topics discussed in the Staff’s letter as well as any material developments to our risk oversight structure.

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Should the Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact Allison Blais, Vice President and Associate General Counsel, Corporate, at blais@adobe.com or me at danarao@adobe.com.

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Please expand upon the role that your Lead Director plays in the leadership of the board. For example, please enhance your disclosure to address whether or not your Lead Director may: • represent the board in communications with shareholders and other stakeholders; • require board consideration of, and/or override your CEO on, any risk matters; or • provide input on design of the board itself.

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Please expand upon how your board administers its risk oversight function. For example, please disclose: • why your board elected to retain direct oversight responsibility for monitoring and assessing strategic risk exposure rather than assign oversight to a board committee; • the timeframe over which you evaluate risks (e.g., short-term, intermediate-term, or long-term) and how you apply different oversight

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standards based upon the immediacy of the risk assessed; • whether you consult with outside advisors and experts to anticipate future threats and trends, and how often you re-assess your risk environment; • how the board interacts with management to address existing risks and identify significant emerging risks; • whether you have a Chief Compliance Officer and to whom this position reports; and • how your risk oversight process aligns with your disclosure controls and procedures. 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.

See the reply above.