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Qualcomm Incorporated
5775 Morehouse Drive
San Diego, CA 92121
www.qualcomm.com
April 5, 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 December 24, 2017
Filed January 31, 2018
File No. 000-19528
Dear Ms. Etheredge:
We are writing in response to your letter dated April 2, 2018 (the “Comment Letter”) setting forth a comment 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 April 3, 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 April 30, 2018.
Thank you for your consideration.
Very truly yours,
/s/ David Zuckerman
 
David Zuckerman
Senior Vice President, Legal Counsel and Assistant Secretary
cc:
George Davis, Executive Vice President and Chief Financial Officer, QUALCOMM Incorporated
 
Donald J. Rosenberg, Executive Vice President, General Counsel and Corporate Secretary, QUALCOMM Incorporated
 
Douglas Rein, DLA Piper LLP (US)