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                             April 15, 2021

       Zachary Kirkhorn
       Chief Financial Officer
       Tesla, Inc.
       3500 Deer Creek Road
       Palo Alto, CA 94304

                                                        Re: Tesla, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2020
                                                            Filed February 8,
2021
                                                            File No. 001-34756

       Dear Mr. Kirkhorn:

              We have reviewed your filing 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 Filed February 8, 2021

       Financial Statements
       Consolidated Statements of Operations, page 55

   1.                                                   We note the sale of
regulatory credits has increased substantially in 2020 and now exceeds
                                                        your revenues from
other activities such as automotive leasing. As regulatory credit
                                                        sales represent sales
of an intangible asset, it appears you should either present the
                                                        revenues separately as
their own source of revenue or present them in your "Services and
                                                        other" category to
avoid investor confusion. We further note your inclusion of the sales
                                                        of regulatory credits
in Automotive Sales is favorably impacting your gross profit metrics,
                                                        which could lead to
further investor confusion regarding the nature and quality of your
                                                        automotive sales
margins. This comment also applies to your tabular presentation within
                                                        your Results of
Operations discussion on page 40 of MD&A. Please refer to Rule 5-
                                                        03(1) of Regulation S-X
for guidance.
 Zachary Kirkhorn
Tesla, Inc.
April 15, 2021
Page 2


        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 Kevin Stertzel at (202) 551-3723 if you have questions
regarding
comments on the financial statements and related matters.



FirstName LastNameZachary Kirkhorn                        Sincerely,
Comapany NameTesla, Inc.
                                                          Division of
Corporation Finance
April 15, 2021 Page 2                                     Office of
Manufacturing
FirstName LastName