October 31, 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 September 19, 2019 response to our comment letter
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. Unless we note otherwise, our references to prior comments are to
comments in our
August 23, 2019 letter.

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

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Segment Net Revenues, page 48

1.    We note your response to prior comment 3. However, we also note that
within your
      segment discussion there are numerous factors impacting revenue for each
segment. For
      instance, the Activision segment was impacted by higher revenues from the
Destiny 2,
      Call of Duty WWII, Call of Duty: Black Ops 4, Spryo Reignited Trilogy,
which were offset
      by lower revenues from Call of Duty: Infinite Warfare. Tell us your
consideration to
      include a quantified discussion (either in dollars or percentage change)
of the franchises or
      titles that materially impacted your revenues for a particular segment.
 Dennis Durkin
FirstName Blizzard, Inc.
Activision LastNameDennis Durkin
Comapany NameActivision Blizzard, Inc.
October 31, 2019
Page 2
October 31, 2019 Page 2
FirstName LastName
Consolidated Statements of Operations, page F-4

2.       We note from your response to prior comment 4 that product sales
include full games sold
         at retail stores and through digital storefronts. Please clarify
whether revenue for both the
         license to the game and the online functionality are included in
product revenue. If so,
         explain further how you determined that the various online services
provided in your
         games should be considered product revenue despite what your customers
believe they are
         purchasing. In this regard, specifically address how you considered
Rule 5-03(b)(1) and
         (2) in classifying your online services as product revenue.
3.       Please provide us with a breakdown of your revenue by when such
revenue is recognized
         (i.e. point-in-time vs. over-time). Also, tell us whether you
considered including this
         information in your footnote disclosures or in management's discussion
and analysis to
         provide investors with further insight into the timing and source of
your revenue.
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page F-17

4.       We note your responses to prior comments 5, 6 and 10. We continue to
evaluate your
         responses and may have further comments.
Online Hosted and Subscription Arrangements, page F-17

5.       We note your response to prior comment 8. Please further explain how
you determined
         that the software license and the other online activities in your
subscription arrangements
         are highly interrelated and interdependent. In addition, tell us if
you believe the standalone
         selling price of the software license would be significant in
subscription arrangements that
         extend beyond one month. To the extent you do not recognize a software
license as a
         separate performance obligation in your subscription arrangements,
please explain further
         your disclosures on page 68 which state that the purchase of World of
Warcraft software
         is classified as "Product sales" whereas revenues attributable to
subscriptions are
         classified as "Subscription, licensing and other revenues." Lastly,
clarify whether the
         expansion packs sold with your WoW subscriptions are available in both
offline and
         online gameplay.
Other Revenues, page F-18

6.       You state in your response to prior comment 9 that revenue from the
sale of durable
         virtual goods is recognized over the period of time the good is
available to the player and
         your performance obligation is satisfied, which is generally the
estimated service period.
         Please clarify whether you recognize revenue from the sale of such
goods over the service
         period remaining at the point in which the good was purchased.
Alternatively, if the
         service period for the virtual goods extends beyond the remaining
service period for the
         game, please explain why and tell us the specific guidance you
considered.
 Dennis Durkin
Activision Blizzard, Inc.
October 31, 2019
Page 3


      You may contact David Edgar, Staff Accountant, at (202) 551-3459 or
Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions.



FirstName LastNameDennis Durkin                         Sincerely,
Comapany NameActivision Blizzard, Inc.
                                                        Division of Corporation
Finance
October 31, 2019 Page 3                                 Office of Technology
FirstName LastName