August 28, 2019

Andrew Wilson
Chief Executive Officer
Electronic Arts, Inc.
209 Redwood Shores Parkway
Redwood City, California 94065

       Re: Electronic Arts, Inc.
           Form 10-K for the Fiscal Year Ended March 31, 2019
           File No. 000-17948

Dear Mr. Wilson:

       We have reviewed your July 31, 2019 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in
our July 18, 2019 letter.

Form 10-K for the Fiscal Year Ended March 31, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 33

1.    We note from your response to prior comment 1 that the majority of your
digital revenues
      are from sales of extra content for each fiscal year presented. Please
tell us your
      consideration of providing qualitative and quantitative analysis
disclosure of extra content
      sales. Such analysis should explain the trends and underlying causes for
increases across
      your live services and mobile revenues attributable to those sales of
extra content. We
      refer you to the Commission Guidance Regarding Management's Discussion
and Analysis
      of Financial Condition and Results of Operations, Release No. 33-8350.
 Andrew Wilson
FirstName Arts, Inc.
Electronic LastNameAndrew Wilson
Comapany NameElectronic Arts, Inc.
August 28, 2019
August 28, 2019 Page 2
Page 2
FirstName LastName
Consolidated Financial Statements
Description of Business and Basis of Presentation
Revenue Recognition, page 53

2.       In order for us to better understand your analysis and response to
prior comment 2, please
         provide a more specific discussion of the underlying nature of your
in-game content. In
         this regard, please tell us if and how content can transfer a benefit
to a player beyond the
         time the content is purchased. In addition, tell us if and how the
estimated offering period
         for the content differs from that of the game.
3.       We note your response to prior comment 3. Please further explain how
you considered
         the fact that the online hosting allows for multiple player use in
determining that you have
         met the allocation objective. We refer you to ASC 606-10-32-28.
4.       Specifically with regards to the performance obligation related to
online functionality,
         please help us understand the different roles and responsibilities
that you and your
         platform partners have with respect to technology, host
configurations, maintenance and
         services. Tell us whether you use your own or third-party servers to
host the multiplayer
         or online game play and describe the interaction of your online
functionality with Sony
         and Microsoft's platforms. Compare and contrast the different service
obligations that you
         and your platform partners have with respect to the players who
purchase your games and
         how such obligations factored into your determination of the
standalone selling price and
         the transaction price allocation for your game related services.
5.       Please confirm to us that your full games with online-only
functionality, which require an
         Internet connection to access all gameplay and functionality
("Online-Hosted Service
         Games") do not contain a software license. If the arrangement does
contain a license,
         provide us with your analysis of the factors considered in determining
that the software
         and online hosting are not separately identifiable. We refer you to
ASC 606-10-25-21.
6.       We note that revenue from subscriptions, such as Origin Access, Origin
Access Premier
         and EA Access, is recognized over the subscription term. We further
note that
         subscriptions are offered for a recurring monthly or annual fee.
Please tell us whether
         these arrangements contain a license and, if so, how you determined
that revenue for
         arrangements that extend beyond one month should be recognized over
time.
 Andrew Wilson
Electronic Arts, Inc.
August 28, 2019
Page 3

      You may contact Morgan Youngwood, Staff Accountant, at 202-551-3479 or
Craig
Wilson, Senior Assistant Chief Accountant, at 202-551-3226 with any questions.



                                                      Sincerely,
FirstName LastNameAndrew Wilson
                                                      Division of Corporation
Finance
Comapany NameElectronic Arts, Inc.
                                                      Office of Information
Technologies
August 28, 2019 Page 3                                and Services
FirstName LastName