SecProbe.io

May 12, 2009
Via U.S. Mail and Facsimile (408-653-6796)

Stacy J. Smith Vice President and Chief Financial Officer Intel Corporation 2200 Mission College Boulevard Santa Clara, California 95054-1549

 Re: Intel Corporation
  Form 10-K for the Fiscal Year Ended December 27, 2008
  Filed February 23, 2009   File No. 0-06217
Dear Mr. Smith:

We have limited our review of your f ilings to disclosure relating to your
contacts with countries that have been identified as state sponsors of terrorism, and we
have the following comment.  Our review w ith respect to this issue does not preclude
further review by the Assistant Director  group with respect to other issues.   At this
juncture, we are asking you to provide us with supplemental information, so that we
may better understand your disclosure.  Please be as detailed as necessary in your response.  After reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comment or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 General

1. It appears from page 15 of your Form 10- K and the “Intel in  the Middle East”
section of your website that you have ope rations in the Middle East and Africa,
which are regions that include Iran, Syri a, and Sudan.  In addition, we are aware
of a May 2008 news report that PCs in Cuba contain your Celeron processors.
Cuba, Iran, Sudan, and Syria are identifie d by the State Department as state
sponsors of terrorism, and are subject to  U.S. economic sanctions and export
controls.  We note that your Form 10-K  does not include disclosure regarding
contacts with Cuba, Iran, Sudan, and Syria.   Please describe to us the nature and
extent of any past, current, and anticipate d contacts with the referenced countries,
whether through distributors, resellers, li censees, or other direct or indirect
arrangements.  Your response should describe any produc ts or technology you
have provided to the referenced countr ies, directly or indirectly, and any
agreements, commercial arrangements, or  other contacts you have had with the
governments of those countries or entit ies controlled by those governments.

Stacy J. Smith
Intel Corporation May 12, 2009 Page 2
* * * * *

Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Pleas e submit your response letter on EDGAR.
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that th e filings include all in formation required under
the Exchange Act of 1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its management are in possession of all facts relating to the company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
 In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;
 • staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

Please understand that we may have addi tional comments after we review your
response to our comment.  Pl ease contact Pradip Bhaumik, Special Counsel, at (202) 551-
3333 if you have any questions about the commen t or our review.  You may also contact
me at (202) 551-3470.          S i n c e r e l y ,             C e c i l i a  B l y e ,  C h i e f          Office of Global Security Risk   cc:  Peggy Fisher   Assistant Director  Division of Corporation Finance