October 31, 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 September 12, 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 August 28,
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 growth in extra
content has been
      critical to your digital transformation. With a view toward future
disclosure of this trend,
      please provide 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. See Item
      303(a)(3) of Regulation S-K and the related Instructions to paragraph
303(a).
Consolidated Financial Statemetns
Description of the Business and Basis of Presentation
Revenue Recognition, page 53
 Andrew Wilson
Electronic Arts, Inc.
October 31, 2019
Page 2
2.       Your response to prior comment 2 indicates that the estimated offering
period for future
         update rights and the online hosting service are the same for in-game
content and full
         game sales. Please help us understand why revenue for in-game content
would not begin
         to be recognized when the content was purchased. In addition, please
indicate whether the
         estimated offering period for sales of in-game content can exceed the
estimated service
         period of the updates rights and the online hosting services or
whether you extend the
         estimated service periods for the sold items.
3.       We are continuing to evaluate your responses to prior comments 3 of
our letters dated July
         18, 2019 and August 28, 2019, and may have additional comments.
4.       We note from your disclosures on page 29 that games sold at retail
have a composite
         offering period equal to the online gameplay period plus time in the
channel and the
         service related performance obligations are generally recognized over
an estimated nine
         month period beginning in the month after shipment. Please help us
understand why
         revenue for these performance obligations does not begin to be
recognized upon a sale of
         a game to the end user.
5.       Your response to prior comment 6 indicates that your subscription
offerings provide
         subscribers with a license to current games included with the
subscription. Please further
         clarify how you considered ASC 606-10-25-21 in determining that the
license does not
         represent a separate performance obligation. In addition, please help
us understand if you
         believe the standalone selling price of licenses in arrangements that
extend beyond one
         month would be significant.
      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.



FirstName LastNameAndrew Wilson                              Sincerely,
Comapany NameElectronic Arts, Inc.
                                                             Division of
Corporation Finance
October 31, 2019 Page 2                                      Office of
Technology
FirstName LastName