SEC Comment Letter 0000000000-23-008376 to ADVANCED MICRO DEVICES INC (AMD) (CIK 0000002488) (AMD)
ADVANCED MICRO DEVICES INC (AMD) (CIK 0000002488)
Date: Aug. 3, 2023 · CIK: 0000002488 · Accession: 0000000000-23-008376
AI Filing Summary & Sentiment
File numbers found in text: 001-07882
Show Raw Text
United States securities and exchange commission logo
August 3, 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
Filed February 27, 2023
File No. 001-07882
Dear Jean Hu:
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 31, 2022
General
1.We note that you provided more expansive disclosure in your 2021-22 Corporate
Responsibility Report and Environmental Sustainability section of your website than you
provided in your SEC filings. Please advise us what consideration you gave to providing
the same type of climate-related disclosure in your SEC filings as you provided in your
2021-22 Corporate Responsibility Report and website.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
40
2.To the extent material, discuss the indirect consequences of climate-related regulation or
business trends, such as the following:
•decreased demand for goods or services that produce significant greenhouse gas
emissions or are related to carbon-based energy sources;
FirstName LastNameJean Hu
Comapany NameAdvanced Micro Devices, Inc.
August 3, 2023 Page 2
FirstName LastName
Jean Hu
Advanced Micro Devices, Inc.
August 3, 2023
Page 2
•increased demand for goods that result in lower emissions than competing products;
•increased competition to develop innovative new products that result in lower
emissions;
•increased demand for generation and transmission of energy from alternative energy
sources; and
•any anticipated reputational risks resulting from operations or products that produce
material greenhouse gas emissions.
3.We note your disclosure on page 35 of your Form 10-K regarding the impact of the
physical effects of climate change. If material, discuss the physical effects of climate
change on your operations and results. This disclosure may include the following:
•severity of weather, such as water availability and quality;
•quantification of material weather-related damages to your property or operations;
•potential for indirect weather-related impacts that have affected or may affect your
customers; and
•any weather-related impacts on the cost or availability of insurance.
Your response should include quantitative information for each of the periods for which
financial statements are presented in your Form 10-K and explain whether changes are
expected in future periods.
4.If material, please discuss any purchase or sale of carbon credits or offsets and the effects
on your business, financial condition, and results of operations. To the extent applicable,
ensure you provide quantitative information with your response for each of the periods for
which financial statements are presented in your Form 10-K and for any future periods.
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 Anuja Majmudar, Staff Attorney, at (202) 551-3844 or Karina Dorin, Staff
Attorney, at (202) 551-3763 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation