QUALCOMM INC/DE — Director's Dealing 2010

Jan 5, 2010

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: QUALCOMM INC/DE (QCOM)
CIK: 0000804328
Period of Report: 2009-12-31

Reporting Person: KEITEL WILLIAM E (EVP & Chief Financial Officer)

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2009-12-31	Phantom Stock Unit	$1	A	2528	Acquired		Common Stock (2528)	Indirect

Footnotes

F1: The common stock issued under the terms of the Company's Executive Retirement Matching Contribution Plan, a tax conditioned plan, is exempt under Rule 16b-3. The shares are held in a grantor trust and stock is the only permissable form of distribution under the Plan.

F2: The rights awarded under the Company's Executive Retirement Matching Contribution Plan will be eligible for distribution upon termination and vest according to the following schedule: 100% at age 65 with acceleration provisions (1) at the rate of 25% per year for each subsequent year of participation, (2) after the individual reaches age 61, or (3) if they have more than 10 years of service.

F3: The rights awarded under the Company's Executive Retirement Matching Contribution Plan will be eligible for distribution upon termination.