SecProbe.io

June 4, 2015

Via Email
Mr. Stacy J. Smith
Executive Vice President and Chief Financial Officer
Intel Corporation
2200 Mission College Boulevard
Santa Clara, California 95054

Re: Intel Corporation
Form 10 -K for the Fiscal Year Ended December 27, 2014
Filed February 13, 2015
Form 10 -Q for the Fiscal Quarter Ended March 28, 2015
Filed April 27, 2015
File No. 000-06217

Dear Mr. Smith :

We have reviewed your filing an d 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 busine ss days by providing the requested
information or advis e 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 27, 2014

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 31

Mobile and Communications Group, page 39

1. You disclo se that the $1.2 billion decrease in Mobile and Communications Group
revenue in 2014 arose from higher cash consideration paid to customers and lower phone
component sales partially offset by higher tablet platform unit sales.  To help us better
understand  your disclosure please quantify for us the impact on revenues of lower prices,
including the impact of cash consideration paid to customers, and offsetting higher unit
sales.  In light of the apparent significance of the offsetting components of price and

Mr. Stacy J. Smith
Intel Corporation
 June 4, 2015
Page 2

 volume in 2014, explain to us how your disclosure considers the guidance about known
trends from Item 303(a)(3)(ii) of Regulation S -K.

Item 8.  Financial Statements

Note 26.  Operating Segments and Geographic Information, page 113

2. We note that in 2015  you reorganized your business to combine the PC Client Group
segment and Mobile and Communications Group segment to form a new Client
Computing Group operating segment.   We also note that your pre - and post -
reorganization segments each include numerous pr oduct platforms.   To help us better
understand how you apply FASB ASC Topic 280 in identifying reportable segments and
how the business reorganization lead to the revised segment reporting structure, please
respond to the following for both pre - and post -reorganization:

 Tell us the title and describe to us the role of each of the individuals who report to
the Chief Operating Decision Maker (CODM).
 Please identify and describe to us the role of each of your segment managers.
 Describe to us the information regularly provided to the CODM and how
frequently it is prepared.
 Similarly, describe to us the financial information provided to the Board and how
frequently it is prepared.
 Explain to us how budgets are prepared, who appr oves the budget at each step of
the process and describe the level of detail discussed at each step.
 Tell us how often the CODM meets with his staff to discuss variances between
actual and budgeted results.
 Describe the level of detail communicated to the  CODM when actual results
differ from budgets and clarify who is involved in meetings with the CODM to
discuss budget variances.
 Describe the basis for determining segment manager compensation.

3. In the description of your business under “Products” and “Products and Product Strategy
by Operating Segment” you describe numerous products and platforms; however, we do
not see product line disclosure in the notes to your financial statements.   Explain to us
your consideration of the guidance from FASB ASC 280 -10-50-40.

Form 10 -Q for the Fiscal Quarter Ended March 28, 2015

Results of Operations – First Quarter of 2015 compared to First Quarter of 2014

Client Computing Group, page 34

4. We note that you cite several factors in describing the overall decrease in net revenue for
the CCG operating segment during the first quarter of 2015.  Please quantify for us the

Mr. Stacy J. Smith
Intel Corporation
 June 4, 2015
Page 3

 impact on revenues of each of the factors cited in the disclosure.  Also, quantify for us the
impact on revenues from changes in prices and changes i n volume during the quarter.  To
enhance an investor’s understanding, please revise the discussion in future filings to
include this information.

5. We note the CCG segment is approximately 60% of your revenues and includes
numerous products and product pl atforms as described in your filings.  However, we see
that your discussion does not provide quantification to clarify the underlying composition
of the segment’s revenues or to quantify concentrations from any particular product or
product platform.  Acco rdingly, in future filings, please revise the section to quantify the
components of the segment’s revenues.

6. We see that CCG operating income decreased by $437 million which was driven by $499
million of lower gross margin.  We also note that gross margin was positively impacted
by $260 million of lower factory start -up costs.  Please revise future filings to provide
further clarity of the underlying reasons for the significant decline in gross margin,
considering the offsetting impact of the lower factory start-up costs.  Further, revise
future filings to explain how the 8% decrease in revenues contributed to such a
significant decrease in gross margin.  Provide us with your proposed disclosure.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny 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 provide  a written statement from the co mpany
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the
United States.

Mr. Stacy J. Smith
Intel Corporation
 June 4, 2015
Page 4

 You may contact Kristin Lochhead at (202) 551 -3664  or Gary Todd,  Senior  Accountant ,
at (202) 551 -3605  if you have questions regarding comments on the financial statements and
related matters.   Please contac t Jay Mumford  at (202) 551 -3637  or Geoff Kruczek , Senior
Attorney , at (202) 551 -3641 with any other questions.

Sincerely,

 /s/Gary Todd for

Brian Cascio
Accounting Branch Chief