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                          November 12, 2020

       Donald J. Rosenberg
       Executive Vice President, General Counsel, and Corporate Secretary
       QUALCOMM Incorporated
       5775 Morehouse Drive
       San Diego, CA 92121-1714

                                                        Re: QUALCOMM
Incorporated
                                                            Registration
Statement on Form S-4
                                                            Filed November 5,
2020
                                                            File No. 333-249871

       Dear Mr. Rosenberg:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Edward
M. Kelly, Senior Counsel, at (202) 551-3728 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Manufacturing
       cc:                                              D. Scott Bennett, Esq.