SecProbe.io

March 21, 2012
 Via Email

Mr. Stacy J. Smith Senior Vice President and Chief Financial Officer Intel Corporation 2200 Mission College Boulevard Santa Clara, California 95054
Re: Intel Corporation
 Form 10-K for the Year Ended December 31, 2011
Filed February 23, 2012 File No. 000-06217

Dear Mr. Smith:
 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 this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 8-K dated January 19, 2012, filed January 20, 2012

 1. We note that you present non-GAAP measures  for revenues, gross margin, operating
income, net income and earnings per share on page 2 of exhibit 99.1, but that you did not
use a title for each measure that clearly dis tinguishes it from its directly comparable
GAAP measure. Instead we note that you simply used an asterisk cross-referenced to a
footnote at the bottom of the page to tell investors that the amount presented in each
bullet point is a non-GAAP measure. Tell us how  this presentation complies with Items
10(e)(1)(i)(A) and 10(e)(1)(ii)(E ) of Regulation S-K.  Otherw ise, please confirm that in
future filings you will revise your presenta tion of non-GAAP measures to fully comply
with those requirements.

Mr. Stacy J. Smith Intel Corporation March 21, 2012 Page 2

 Form 10-K for the year ended December 31, 2011

 Item 1.  Business, page 1

 2. To the extent that recent developments in the supply of and access to rare earth metals
have affected or are likely to affect your bus iness, provide the disc losure required by Item
101(c)(1)(iii) of Regulation S-K.  In additi on, if access to rare earth metals by you, your
suppliers or customers creates uncertainties or risks for your business, please provide risk
factor or trends disclosu re pursuant to Items 503(c) and 303 of Regulation S-K.
 Third parties may attempt . . ., page 15

3. We note that at a press event on March 6, 2012, Diane Bryant, your Vice President and
General Manager, Data Center and Connected  Systems Group, stated that “the [IT and
security] environment we are all living in ju st continues to increase in intensity. The
number of attacks to our environment is doubl ing every year. The sophistication of those
attacks is getting more intense.”  Please te ll us what consideration you gave to including
disclosure describing these particular charact eristics of your security environment and the
implications of such rapid a nd significant increases in the threats to that environment.
Please refer to the Division of Corporation Fi nance’s Disclosure Guidance Topic No. 2 at
http://www.sec.gov/divisions/corpfin /guidance/cfguidance-topic2.htm  for additional
information.
 Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page
23
 Results of Operations, page 29

 4. Please tell us and, in your future filings pr ovide, a clear and quantif ied discussion of the
underlying material causes of changes in your  overall net revenues and overall gross
margins, as well as similar changes in related segment results.  We note in this regard that your current disclosure merely re fers to general causes such as significantly higher
platform average selling prices or slightly higher  platform unit sales, but does not explain
the reasons for these changes or quantify how each factor c ontributed to the period over
period increases.  Refer to the instructions  to Item 303 of Regul ation S-K and section
III.B.4 of SEC Interpretive Release No. 33-8350.
5. As a related matter, we note your disclosure  on page 13 that your financial results,
including average selling prices, are affected  by the “mix of microprocessors” and “mix
of other products” sold. With a view toward clarified disclo sure, please tell us how the
classes of products you mention affect average selling prices and the affect each class has
on margins. Also tell us, with a view to ward disclosure, where your document includes
the three-year revenue history of those clas ses and the effect of new product introductions
on product mix during the periods presented.  See Regulation S-K Item 101(c)(1)(i).

Mr. Stacy J. Smith Intel Corporation March 21, 2012 Page 3

 Financial Statements

 Note 30: Operating Segment and Geographic Information, page 92

 6. Tell us where you have disclosed the amount of depreciation, deplet ion, and amortization
expense included in each segment’s results  as required by FA SB ASC 280-10-50-22.
While you disclose that your CODM does not ev aluate operating segments using discrete
asset information, we note that one of the m easures used to evaluate segment results is
operating income (loss), of which depreciati on and amortization expense is a component.
If you concluded that the disc losure was not required, pleas e tell us why and explain how
you considered ASC 280-10-55-12 through 55-15  in reaching your conclusion.

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:

 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Julie Sherman at (202) 551-3640 or Jay Webb at (202) 551-3603 if you
have questions regarding comments on the financ ial statements and related matters.  Please
contact Geoff Kruczek at (202) 551-3641 or me  at (202) 551-3528 with any other questions.

Sincerely,
   /s/ Amanda Ravitz
Amanda Ravitz Assistant Director