Form: UPLOAD

SEC-generated letter

September 8, 2023

Published on September 8, 2023

United States securities and exchange commission logo





September 8, 2023

Jean Hu
Executive Vice President, Chief Financial Officer and Treasurer
Advanced Micro Devices, Inc.
2485 Augustine Drive
Santa Clara, CA 95054

Re: Advanced Micro
Devices, Inc.
Form 10-K for the
fiscal year ended December 31, 2022
Response dated
August 31, 2023
File No. 001-07882

Dear Jean Hu:

We have reviewed your August 31, 2023 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 3, 2023 letter.

Response dated August 31, 2023

Management's Discussion and Analysis of Financial Condition and Results
of Operation, page
40

1. We note your response
to prior comment 2 states that you did not identify any indirect
consequences of
climate-related regulation or business trends for purposes of your
reporting to the
Commission. Please include a discussion explaining in greater detail your
analysis and how you
concluded on the materiality of each of the items for which
disclosure was not
deemed necessary. For example, explain how you determined that your
customer's interest in
reducing greenhouse gas emissions and using alternate energy
sources did not
correlate to increases or decreases in demand for your products and
technologies. In that
regard, we note your CDP Climate Change submission reflects that
you work closely with
customers to identify climate challenges and solutions and engage
Jean Hu
Advanced Micro Devices, Inc.
September 8, 2023
Page 2
customers on matters related to energy efficiency and climate in order
to inform your
product design and other environmental initiatives. Please also tell
us how you considered
the impact that climate-related regulation or business trends of your
suppliers, including
the manufacturers of your wafer supplies, may have on your business
and operations.

In addition, we note your response reflects that you do not currently
anticipate any
material reputational risks resulting from your operations or products
that produce
material greenhouse emissions. Please expand your disclosure to
discuss the potential
adverse consequences to your reputation resulting from your operations
that produce
greenhouse gas emissions.
2. We note your response to prior comment 3. Please further address the
following:
Your response states that you did not consider water risks to be
material for purposes
of reporting in your Form 10-K, although your 2021-2022 Corporate
Responsibility
Report and CDP Water Submission indicates that the impact of water
availability and
quality is material to your direct wafer manufacturing suppliers.
Please tell us how
you considered disclosure regarding the impact of water
availability and quality in
the manufacturing of your products, including your determination of
materiality on
your business and operations.
Please revise your disclosure to more clearly address how you
could be impacted if
severe weather impacts your customers. In this regard, we note your
disclosure on
page 9 of your Form 10-K indicating that one customer accounted for
16% of your
consolidated net revenue for the year ended December 31, 2022 and
that a loss of this
customer would have a material adverse effect on your business.
3. We note your response to prior comment 4. Please tell us whether you
expect to purchase
carbon credits or offsets in future periods.
Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or
Karina
Dorin, Attorney-Adviser, at (202) 551-3763 with any questions.



FirstName LastNameJean Hu Sincerely,
Comapany NameAdvanced Micro Devices, Inc.
Division of
Corporation Finance
September 8, 2023 Page 2 Office of Energy &
Transportation
FirstName LastName