QUALCOMM INC/DE — Regulatory Filings 2018

May 7, 2018

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Qualcomm Incorporated

5775 Morehouse Drive

San Diego, CA 92121

www.qualcomm.com

May 7, 2018

Via Edgar

Ms. Lisa Etheredge

Senior Staff Accountant

Division of Corporation Finance

Office of Telecommunications

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re: QUALCOMM Inc.

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

Filed November 1, 2017

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

Filed April 25, 2018

File No. 000-19528

Dear Ms. Etheredge:

We are writing in response to your letter dated May 2, 2018 (the “Comment Letter”) setting forth comments of the Staff (the “Staff”) of the Securities and Exchange Commission relating to the above referenced filings of QUALCOMM Incorporated (the “Company”). Confirming your telephone conference on May 4, 2018 with Douglas Rein of DLA Piper LLP (US), our outside counsel, we understand that the Staff has provided an extension of an additional ten business days for the Company to respond to the Comment Letter. As such, the Company intends to submit its response to the Comment Letter on or before May 31, 2018.

Thank you for your consideration.

Very truly yours,

/s/ David Zuckerman

David Zuckerman

Senior Vice President, Legal Counsel and Assistant Secretary, QUALCOMM Incorporated

cc:
Donald J. Rosenberg, Executive Vice President, General Counsel and Corporate Secretary, QUALCOMM Incorporated
Douglas Rein, DLA Piper LLP (US)