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                           January 26, 2021

       Steve Rai
       Chief Financial Officer
       Blackberry Limited
       2200 University Ave East
       Waterloo, ON N2K 0A7,
       Canada

                                                        Re: Blackberry Ltd.
                                                            Form 10-K for
Fiscal Year Ended February 29, 2020
                                                            Filed April 7, 2020
                                                            Form 10-Q for
Quarterly Periods Ended November 30, 2020
                                                            Filed September 24,
2020
                                                            File No. 001-38232

       Dear Mr. Rai:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for Fiscal Year Ended February 29, 2020

       Management Discussion and Analysis of Financial Condition and Results of
Operations
       Non-GAAP Financial Measures, page 32

   1.                                                   We note your purchase
accounting adjustments related to "Software deferred revenue
                                                        acquired," and
"Software deferred commission expense acquired," in many of
                                                        your adjusted non-GAAP
measures, including adjusted revenue, adjusted net income and
                                                        adjusted EBITDA.
Considering your deferred revenue and commission expense
                                                        were adjusted to fair
value at the time of acquisition pursuant to GAAP, these non-GAAP
                                                        adjustments intended to
eliminate the impact of purchase accounting substitute
                                                        individually tailored
recognition and measurement methods for those of GAAP. Please
                                                        tell us how you
considered the guidance of Question 100.04 of the Division's Non-GAAP
 Steve Rai
Blackberry Limited
January 26, 2021
Page 2
         C&DIs and Rule 100(b) of Regulation G when presenting these measures.
Form 10-Q for Quarterly Periods Ended November 30, 2020

Note 3. Fair Value Measurements, Cash, Cash Equivalents and Investments
Goodwill Impairment, page 15

2.       We note you recorded a $594 million goodwill impairment charge related
to the
         BlackBerry Spark reporting unit during the quarter ended May 31, 2020.
In order to
         provide investors with information to better assess the probability of
future goodwill
         impairment charges, please disclose, if accurate, that the estimated
fair values of the
         reporting units you quantitatively tested for impairment substantially
exceeded their
         carrying values. For any reporting unit whose estimated fair value did
not substantially
         exceed its carrying value, please provide the following additional
disclosures:
             The percentage by which fair value exceeded carrying value at the
date of the most
             recent test;
             The amount of goodwill allocated to the reporting unit;
             A description of key assumptions used and how they were
determined;
             A discussion of the degree of uncertainty associated with key
assumptions and a
             sensitivity analysis of the impact of changes in key assumptions;
and
             A description of potential events and/or changes in circumstances
that could
             reasonably be expected to negatively affect key assumptions.
         Please refer to Item 303(a)(3)(ii) of Regulation S-K and Section V of
the Commission's
         Guidance Regarding Management's Discussion and Analysis of Financial
Condition and
         Results of Operations, SEC Release No. 34-48960.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Joseph Cascarano, Senior Staff Accountant, at (202)
551-3376 or
Robert S. Littlepage, Accountant Branch Chief, at (202) 551-3361 with any
questions.



FirstName LastNameSteve Rai                                   Sincerely,
Comapany NameBlackberry Limited
                                                              Division of
Corporation Finance
January 26, 2021 Page 2                                       Office of
Technology
FirstName LastName