November 5, 2024

Alexander Bradley
Chief Financial Officer
First Solar, Inc.
350 West Washington Street, Suite 600
Tempe, Arizona 85288

       Re: First Solar, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Filed February 27, 2024
           Form 10-Q for the Fiscal Quarter Ended September 30, 2024
           Filed October 29, 2024
           File No. 001-33156
Dear Alexander Bradley:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

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

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

Form 10-Q for the Fiscal Quarter Ended September 30, 2024
Condensed Consolidated Financial Statements
10. Commitments and Contingencies
Product Warranties, page 23

1.     We note you identified manufacturing issues affecting certain Series 7
modules
       manufactured in 2023 and 2024 that may cause the modules to experience
premature
       power loss once installed in the field and that, based on currently
available
       information and certain assumptions and estimates, you believe a
reasonable estimate
       of aggregate losses related to these manufacturing issues will range
from
       approximately $50 million to $100 million. We also note as of September
30, 2024,
       you increased your product warranty liability by the low end of the
range, which you
       recorded as a reduction to revenue. Please address the following:
           More fully explain your basis for recording the increase in your
product warranty
 November 5, 2024
Page 2

           liability that resulted from this change in estimate as a reduction
to revenue and
           explain where and how prior period changes in estimates were
recorded as well as
           where and how product warranties are recorded when products are
sold. Address
           the apparent inconsistency between recording the current period
increase as a
           reduction to revenue with disclosures in MD&A that indicate    cost
of sales also
           includes depreciation of manufacturing plant and equipment,
facility-related
           expenses, environmental health and safety costs, and costs
associated with
           shipping, warranties, and solar module collection and recycling   .
             More fully explain how you determined the range of reasonably
possible losses
           noted above, including the material underlying assumptions. Revise
future filings
           to disclose and discuss the facts and circumstances related to this
change in
           estimate and the material assumptions underlying it and provide a
sensitivity
           analysis to disclose the potential impact that changes in these
assumptions could
           have on your financial statements under Critical Accounting
Estimates in MD&A.
           Revise future filings to also address the expected timeframe over
which the
           additional information related to these manufacturing issues are
expected to
           become available that could result in changes in this estimate
related to the
           product warranty liability.


        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.

       Please contact Dale Welcome at 202-551-3865 or Anne McConnell at
202-551-3709
with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of
Manufacturing