QUALCOMM Incorporated

5775 Morehouse Drive

San Diego, CA 92121

www.qualcomm.com

June 21, 2018

Mr. Robert Littlepage
Accounting Branch Chief
Division of Corporation Finance

Office of Telecommunications
United States Securities and Exchange Commission
Washington, DC 20549

Re: QUALCOMM Incorporated

Form 10-K for the Fiscal Year Ended September 24, 2017

Filed November 1, 2017

Form 10-Q for the Fiscal Quarter Ended March 25, 2018

Filed April 25, 2018

File No. 000-19528

Response dated May 31, 2018

Dear Mr. Littlepage:

QUALCOMM Incorporated (“Qualcomm” or the “Company”) hereby responds to the comment letter dated June 11, 2018 from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on the above-referenced filings and response. To assist your review, the Company has set forth below the Staff’s comment (in bold) followed by the Company’s response.

Form 10-K for the Fiscal Year Ended September 24, 2017

Critical Accounting Estimates

Legal and Regulatory Proceedings, page 53

1. Please revise to more fully describe the specific factors that make it more difficult to reasonably estimate possible losses associated with antitrust and trade regulation investigations. For example, consider incorporating some of the information from the introductory note of your response dated May 31, 2018.

Response:

The Company will comply with the comment in future filings. The Company intends to expand the disclosure in both (i) the “Critical Accounting Estimates” section of the Management Discussion and Analysis of Financial Condition and Results of Operation in future Annual Reports on Form 10-K and (ii) the Commitments and Contingencies note to the financial statements included in future Quarterly Reports on Form 10-Q and Annual Reports on Form 10-K to more fully describe the specific factors that make it more difficult to reasonably estimate possible losses associated with antitrust and trade regulation investigations,

Mr. Littlepage

RE: Qualcomm Incorporated

June 21, 2018

Page 2 of 2

including applicable information (as it may be updated) from the introductory note of the Company’s response dated May 31, 2018.

Respectfully submitted,

QUALCOMM Incorporated

By: /s/ George S. Davis

George S. Davis

Executive Vice President and Chief Financial Officer

cc:	Donald J. Rosenberg
	Executive Vice President, General Counsel and Corporate Secretary
	Cameron Jay Rains
	Partner, Global Co-CEO and Americas Co-Chairman, DLA Piper LLP (U.S.)