United States securities and exchange commission logo January 19, 2022 Nikesh Arora Chief Executive Officer Palo Alto Networks, Inc. 3000 Tannery Way Santa Clara, CA 95054 Re: Palo Alto Networks, Inc. Form 10-K for Fiscal Year Ended July 31, 2021 File No. 001-35594 Dear Mr. Arora: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Technology cc: Jose F. Macias