QUALCOMM INC/DE — Director's Dealing 2010

Oct 4, 2010

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: QUALCOMM INC/DE (QCOM)
CIK: 0000804328
Period of Report: 2010-09-30

Reporting Person: SULLIVAN DANIEL L (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2010-10-01	Common Stock	M	75000	$43	Acquired	89932	Indirect
2010-10-01	Common Stock	S	75000	$45.4866	Disposed	14932	Indirect

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2010-10-01	Non-Qualified Stock Option (right to buy)	$43	M	75000	Disposed	2010-11-16	Common Stock (75000)	Direct
2010-09-30	Phantom Stock Unit	$1	A	178	Acquired		Common Stock (178)	Indirect

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	4684	Direct

Footnotes

F1: Securities held by Daniel L. Sullivan & Kathryn Sullivan, Trustees of the Sullivan Family Trust dtd. 9/2/99.

F2: The transaction was conducted under a 10b5-1 Plan, as defined under the Securities Exchange Act of 1934, as amended.

F3: The sale prices for this transaction ranged from $45.33 to $45.55. The filer hereby agrees to provide, upon request, full information regarding the number of shares sold at each separate price.

F4: The options vest 10% on the six month anniversary of the date of grant and the remaining balance vests monthly thereafter. The option is fully vested five years after the date of grant.

F5: 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.

F6: 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.

F7: The rights awarded under the Company's Executive Retirement Matching Contribution Plan will be eligible for distribution upon termination.