September 23, 2019

Akash Palkhiwala
Interim Chief Financial Officer
QUALCOMM Incorporated
5775 Morehouse Dr
San Diego, CA 92121-1714

       Re: QUALCOMM Incorporated
           Form 10-K for the Fiscal Year Ended September 30, 2018
           Filed November 7, 2018
           Form 10-Q for the Fiscal Quarter Ended June 30, 2019
           Filed July 31, 2019
           File No. 000-19528

Dear Mr. Palkhiwala :

       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 Fiscal Year Ended September 30, 2018

Item 1. Business, page 4

1.    In your letter to us dated March 21, 2016, you discussed contacts with
Syria and Sudan.
      As you are aware, Syria and Sudan are designated by the State Department
as state
      sponsors of terrorism and are subject to U.S. economic sanctions and/or
export
      controls.Your Form 10-K does not provide disclosure about those
countries. Please
      describe to us the nature and extent of any past, current, and
anticipated contacts with
      Syria and Sudan since your 2016 letter, including contacts with those
countries'
      governments, whether through subsidiaries, distributors, customers,
affiliates, or other
      direct or indirect arrangements.
2.    Please discuss the materiality of any contacts with Syria and Sudan, in
quantitative terms
      and in terms of qualitative factors that a reasonable investor would deem
important in
 Akash Palkhiwala
QUALCOMM Incorporated
September 23, 2019
Page 2
         making an investment decision.
3.       Please tell us whether any of the contacts with Syria and Sudan you
discuss above involve
         dual use products or components.
4.       On page 13, you disclose that Huawei licenses your technology. Huawei
and some of its
         affiliates were added to the Department of Commerce's Entity List in
May 2019 because
         of certain business with Iran, a country also designated as a state
sponsor of terrorism.
         Subsequent news articles have reported on the effects on Qualcomm and
other companies
         of a conditional ban on sales to Huawei. A May 2019 article stated
that your reported
         suspension of business operations with Huawei caused a 3.9% decrease
in your stock
         price. Please discuss for us the risk of reputational harm from your
relationship with
         Huawei.
Form 10-Q for the Fiscal Quarter Ended June 30, 2019

Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Segment Results
QCT Segment, page 36

5.       In future filings, please discuss the underlying factors that caused
your MSM sales to
         decline, including but not limited to the impact of the Huawei export
ban. Please also
         address the future anticipated impact of the ban on unit volumes,
pricing and product mix.
         In this regard, we note your fourth quarter FY 2019 guidance
projecting a 40% year-over-
         year decline in MSM chip shipments. Refer to Item 303 of Regulation
S-K.



        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 Kathryn Jacobson, Senior Staff Accountant at (202)
551-3361 or Robert
Littlepage, Accontant Branch Chief at (202) 551-3361 if you have any questions.



FirstName LastNameAkash Palkhiwala                            Sincerely,
Comapany NameQUALCOMM Incorporated
                                                              Division of
Corporation Finance
September 23, 2019 Page 2                                     Office of
Telecommunications
FirstName LastName