United States securities and exchange commission logo July 20, 2020 Devinder Kumar Chief Financial Officer 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 28, 2019 Filed February 4, 2020 File No. 1-07882 Dear Mr. Kumar: We have reviewed your filing 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 the fiscal year ended December 28, 2019 Management's Discussion and Analysis of Financial Condition and Results of Operations Critical Accounting Estimates, page 35 1. Please enhance your critical accounting estimate disclosures to more fully address the following: We note you establish provisions for rights of return and price protection on unsold products held by distributors and we note certain OEMs may be entitled to rights of return and rebates under OEM agreements. Explain the material assumptions you used to estimate these provisions, quantify the impact these assumptions had during each period, and discuss the impact potential changes in these assumptions could have on future results. Your disclosures should consider addressing any material differences between assumptions related to distributors and OEMs. We note your disclosures related to inventory valuation. Explain the material assumptions you used to estimate reserves, quantify the impact these assumptions had Devinder Kumar ADVANCED MICRO DEVICES INC July 20, 2020 Page 2 during each period, and discuss the impact potential changes in these assumptions could have on future results. We note your disclosures related to income taxes. Explain the specific facts and circumstances that resulted in you concluding recovery of deferred tax assets is not more likely than not and discuss the potential facts and circumstances that may change that conclusion. Liquidity and Capital Resources Operating Activities, page 38 2. Please quantify and discuss the reasons for material fluctuations in working capital components, including the reasons for increases in accounts receivable, inventories, prepaid expenses and other assets, and accounts payable, accrued liabilities and other. In this regard, we note your reference to higher cash collections; however, we note accounts receivable have increased at a substantially higher rate than revenue. We also note your reference to the timing of accounts payable payments with no explanation why the timing changed. Please enhance your disclosures to discuss the reasons for material variations in working capital components. Consolidated Financial Statements Consolidated Balance Sheets, page 45 3. Please provide roll-forwards of activity in your valuation and qualifying accounts in the notes to the financial statements or in the schedule required by Rule 12-09 of Regulation S-X. Notes to Consolidated Financial Statements NOTE 2: Summary of Significant Accounting Policies Revenue Recognition, page 49 4. Please enhance your revenue recognition disclosures to more fully address the following: Describe your contracts and whether they include multiple elements or single products and services. Explain how you determine each performance obligation and, if applicable, how you estimate standalone selling prices. Address whether estimates for variable consideration are constrained. Regarding revenue for custom products, explain why recognizing revenue over time based on the value of the inventory and expected margin is the most appropriate method. Regarding revenue for licensing agreements, explain the nature of the arrangements FirstName LastNameDevinder Kumar that are used to determine whether revenue is recognized over time or at a point in Comapany time. NameADVANCED MICRO DEVICES INC July 20,Please 2020 refer Page to 2 ASC 606-10-50. FirstName LastName Devinder Kumar FirstName LastNameDevinder Kumar ADVANCED MICRO DEVICES INC Comapany July NameADVANCED MICRO DEVICES INC 20, 2020 July 20, Page 3 2020 Page 3 FirstName LastName 5. Please explain your consideration of providing additional disclosures that disaggregate revenue recognized from contracts with customers into categories that more fully depict how the nature, amount, timing and uncertainty of revenue and cash flows are effected by economic factors. For example, we note that you recognize revenue using both point in time and over time methods and that you sell products to both distributors and OEMs. We also note from your MD&A disclosures and earnings calls that revenue from certain products can substantially impact your margins and results. Please more fully explain your consideration of the provisions of ASC 606-10-50-5 and ASC 606-10-55-89 to 91. 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 Mindy Hooker at 202-551-3732 or Anne McConnell at 202-551-3709 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing