March 13, 2019

Luca Zaramella
Chief Financial Officer
Mondelez International, Inc.
Three Parkway North
Deerfield, IL 60015

       Re: Mondelez International, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed February 8, 2019
           File No. 001-16483

Dear Mr. Zaramella:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Estimates, page 48

1.    We note your disclosure indicating that, in connection with your 2018
annual goodwill
      impairment testing, each of your reporting units had "sufficient" fair
value in excess of
      carrying value. Supplementally, explain to us how you have defined
"sufficient" for
      purposes of this disclosure. Separately, tell us whether any of your
reporting units had a
      fair value that was not substantially in excess of carrying value and
which were therefore
      at risk of goodwill impairment under FASB ASC Topic 350.

      To the extent that reporting units are at risk of goodwill impairment,
explain to us how
      you considered providing the following disclosures:

          The percentage by which fair value exceeded carrying value as of the
date of the most
 Luca Zaramella
Mondelez International, Inc.
March 13, 2019
Page 2
             recent test;
             The amount of goodwill allocated to the reporting unit;
             A description of the methods and key assumptions used and how the
key assumptions
             were determined;
             A discussion of the degree of uncertainty associated with the key
assumptions. The
             discussion regarding uncertainty should provide specifics to the
extent possible (e.g.,
             the valuation model assumes recovery from a business downturn
within a defined
             period of time); and
             A description of potential events and/or changes in circumstances
that could
             reasonably be expected to negatively affect the key assumptions.

Financial Statements and Supplementary Data
Note 13 - Commitments and Contingencies, page 109

2.       You indicate in the last paragraph under the caption Legal Proceedings
that you believe
         the ultimate outcome of the various legal proceedings to which you are
a party,
         individually and in the aggregate, will not materially harm your
financial position, results
         of operations or cash flows. If it is at least reasonably possible
that a loss exceeding
         amounts already recognized may have been incurred and the amount of
that additional
         loss would be material, either disclose the estimated additional loss,
or range of loss, that
         is reasonably possible, or state that such an estimate cannot be made.
Refer to FASB ASC
         paragraph 450-20-50-4 and Question 2 to SAB Topic 5:Y.
       In closing, 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.

       You may contact Jenifer Gallagher, Staff Accountant at (202) 551-3706 or
Brad Skinner,
Senior Assistant Chief Accountant at (202) 551-3489 with any questions.



FirstName LastNameLuca Zaramella                               Sincerely,
Comapany NameMondelez International, Inc.
                                                               Division of
Corporation Finance
March 13, 2019 Page 2                                          Office of
Natural Resources
FirstName LastName