August 22, 2019

Dennis Durkin
Chief Financial Officer
Activision Blizzard, Inc.
3100 Ocean Park Boulevard
Santa Monica, CA 90405

       Re: Activision Blizzard, Inc.
           Form 10-K for the Year Ended December 31, 2018
           Filed on February 28, 2019
           File No. 001-15839

Dear Mr. Durkin:

       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 for the Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Operating Metrics, page 38

1.    We note your reference to the three key metrics of reach, engagement and
player
      investment in the Q1 2019 earnings call. With regards to engagement you
refer to a
      record time spent on the King Network of 38 minutes per daily active user
and you also
      reference overall time spent in your games of 50 minutes. As engagement
appears to be a
      key metric used in monitoring your business, please revise to include a
quantified
      discussion of minutes spent in future filings, or tell us what other
measures management
      uses to assess user engagement and include a quantified discussion of
such measure.
      Refer to Item 303(a)(3) of Regulation S-K and Section III.B.1 of SEC
Release 33-8350.
 Dennis Durkin
FirstName Blizzard, Inc.
Activision LastNameDennis Durkin
Comapany NameActivision Blizzard, Inc.
August 22, 2019
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2.       For your third key metric, player investment, you include a quantified
discussion of in-
         game net bookings in total and a qualitative discussion of how such
measure relates to
         specific segments and/or franchises in your earnings call. In
addition, in your Form 10-K,
         you refer to a shift in your business towards a more consistently
recurring and year-round
         model via the sale of downloadable content and microtransactions. If
in-game net
         bookings is how management measures player investment, please revise
to include a
         quantified discussion of such measure in future filings, or tell us
what other measures
         management uses to assess player investment. Also, tell us the amount
of revenue
         generated from in-game content (e.g. downloadable content and
microtransactions) for
         each period presented by segment. To the extent that in-game content
has been a material
         contributor to your revenue, please consider including a quantitative
and
         qualitative discussion of the impact of such content on both your
total and segment
         revenues. Refer to Item 303(a)(3) of Regulation S-K and Section
III.B.1 of SEC Release
         33-8350.
Segment Net Revenues , page 48

3.       You include a discussion of the various franchise titles that impacted
the net revenue for
         each of your segments. Similarly, you discuss various factors that
impacted your segment
         income from operations. When a material change in revenue or
operations is attributed to
         two or more factors, including any offsetting factors, please quantify
the relative impact of
         each identified factor or explain to us why you believe such
quantification is not
         necessary. Refer to Item 303(a)(3) of Regulation S-K and Section III.D
of SEC Release
         33-6835.
Consolidated Statements of Operations, page F-4

4.       Please provide us with a breakdown of your "subscription, licensing
and other revenues"
         between product and services. In your response, tell us whether you
consider third-party
         licenses, downloadable content and microtransactions as a product or
service. To the
         extent that the service revenue included in this line item is greater
than 10% of total
         revenue, separately present revenue and the related cost of revenues
from product and
         services on the face of your consolidated statement of operations.
Refer to Rule 5-03(b)(1)
         and (2) of Regulation S-X.

Note 2. Summary of Significant Accounting Policies
Revenue Recognition
Products with Online Functionality, page F-17

5.       You state on page F-25 that upon adoption of ASC 606, approximately
20% of the
         arrangement fee for many of the titles within your Call of Duty
franchise are now
         recognized as revenue upon delivery. Please describe for us each of
the performance
         obligations included in your products with online functionality and
clarify how you
 Dennis Durkin
Activision Blizzard, Inc.
August 22, 2019
Page 3
         allocate the remaining 80% of the fee to such performance obligations.
Explain further the
         specific methods, inputs, estimates and assumptions used in
determining the standalone
         selling price for each performance obligation and tell us the
percentage of the transaction
         price allocated to each.
6.       Specifically with regards to the performance obligation related to
online functionality,
         please help us understand the different roles and responsibilities
that you and your
         platform partners have with respect to technology, host
configurations, maintenance and
         services. Tell us whether you use your own or third-party servers to
host the multiplayer
         or online game play and describe the interaction of your online
functionality with Sony
         and Microsoft's platforms. Compare and contrast the different service
obligations that you
         and your platform partners have with respect to the players who
purchase your games and
         how such obligations factored into your determination of the
standalone selling price and
         the transaction price allocation for your game related services.
7.       You state that certain of your franchise titles may contain a license
of your intellectual
         property to play the game offline, but also depend on a significant
level of integration and
         interdependency with the online functionality. You also refer to
recognizing the entire
         arrangement fee for the Black Ops 4 game ratably over the service
period. Please clarify
         whether there are games in which you determined that the license of
the intellectual
         property and the online functionality are accounted for as a single
performance
         obligation. If so, tell us the amount of revenue recognized from such
games for fiscal
         2018 and to date in fiscal 2019 and provide us with your analysis of
the factors considered
         in determining that the software and online functionality are not
separately identifiable.
         Refer to ASC 606-10-25-21.
Online Hosted and Subscription Arrangements, page F-17

8.     Please describe for us in further detail the terms and conditions,
including cancellation
       provisions, for both your online hosting and subscription arrangements.
Clarify how these
       arrangements differ as you refer to the World of Warcraft franchise with
regards to
       both. Describe the performance obligations included in each of these
arrangements. With
       regard to your subscription arrangements, please also address your
separate discussion of
       the World of Warcraft software and expansion packs and clarify whether
these
       products are accounted for separately from the subscription
arrangements. To the extent
       that the software and online services are accounted for as one
performance obligation,
       explain further the factors considered in determining that they are not
both distinct and
       separable. Also, tell us whether either of these arrangements provide
for offline game
FirstName LastNameDennis Durkin
       play. If so, clarify whether such games can be played offline once the
subscription or
Comapany NameActivision Blizzard,cancelled or expires and how that factored
into your
       online hosting arrangement is Inc.
Augustanalysis. Refer to ASC 606-10-25-19 through 25-21.
        22, 2019 Page 3
FirstName LastName
 Dennis Durkin
FirstName Blizzard, Inc.
Activision LastNameDennis Durkin
Comapany NameActivision Blizzard, Inc.
August 22, 2019
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August 22, 2019 Page 4
FirstName LastName
Other Revenues, page F-18

9.       Please describe further for us the nature of your microtransactions
and explain how you
         distinguish between durable and consumable goods. Tell us what product
and/or services
         are transferred to the game-player upon use of such goods and how that
impacts the timing
         of revenue recognition. Please specifically address if the use of a
consumable virtual good
         transfers a benefit to a user beyond the point at which the good is
used. Clarify whether
         the type of game in which the in-game purchase is made (e.g. product
sales, products with
         online functionality, subscriptions, online hosted arrangements, etc.)
impacts the
         accounting for such transaction. Please cite the specific guidance you
relied upon in
         accounting for such sales.
Estimated Service Period, page F-19

10.      You state that the estimated service periods for players of your
current games are
         generally less than 12 months. Tell us whether the service period is
the same for games
         played on each of your platforms (e.g. console, PC and mobile). Also,
tell us whether the
         delivery channel (retail versus digital) has any impact on the service
periods or if the
         service periods differ for online functionality versus in-game
content. To the extent your
         service period varies among platforms, delivery channels, franchises
or performance
         obligations, please revise to provide more granular discussion of the
estimated service
         period in your revenue policy disclosures.
        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 David Edgar, Staff Accountant at 202-551-3459 or Kathleen
Collins,
Accounting Branch Chief at 202-551-3499 if you have any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Information Technologies
                                                              and Services