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November 18, 2022
Anthony DiSilvestro
Chief Financial Officer
Mattel Inc.
333 Continental Blvd.
El Segundo, CA 90245
Re:Mattel, Inc.
Form 10-K for the Year Ended December 31, 2021
Form 10-Q for the Period Ended September 30, 2022
File No. 001-05647
Dear Anthony DiSilvestro:
            We have limited our review of your filing to the financial statements and related
disclosures 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 Year Ended December 31, 2021
Item 1. Business, page 4
1.We note that in 2020, you launched your e-commerce platform, Mattel Creations.  Please
tell us your consideration for disclosing information about this platform including
financial information as well as any risk factors regarding this platform.  For example, we
note that you offer paid annual memberships and related merchandise on this platform as
well as limited edition and exclusive product sales.  Describe the accounting for these
memberships and exclusive sales, including at a segment level, and revise your
disclosures to the extent material.
2.We note your disclosure that you plan to expand your entertainment offerings which
includes various sources of digital content and digital experiences.   Please describe and
expand your disclosures to the extent material, the associated cost structure for your
specific entertainment offerings including your accounting policy for these costs.
Additionally, describe any other associated revenues from these offerings including

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 Comapany NameMattel Inc.
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Mattel Inc.
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advertising revenues, if applicable.
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Application of Critical Accounting Policies and Estimates, page 39
3.We note your discussion of critical accounting estimates that are more
significantly affected by judgments and estimates. Please quantify and provide an analysis
of the impact of critical accounting estimates on your financial position and results of
operations for the periods presented, including the effect of changes in critical accounting
estimates between periods to the extent such changes had a significant effect on your
financial position or operating results. In addition, please revise to include a qualitative
and quantitative analysis of the sensitivity of reported results to changes in assumptions,
judgments, and estimates when reasonably likely changes in assumptions, judgments and
estimates would have a material effect on your financial condition or operating
performance. Refer to Item 303(b)(3) of Regulation S-K.
Notes to Consolidated Financial Statements
Note 1 - Summary of Significant Accounting Policies
Revenue Recognition and Sales Adjustments, page 59
4.Please revise your disclosures to explain the typical billing and payment terms under your
contracts and how the differences in timing of revenue recognition and invoicing your
customers impacts any contract assets or contract liabilities recorded. Further, to the
extent material, please disclose the amounts of contract assets and liabilities and the
amount of revenue recognized in the reporting period that was included in
the contract liability balance at the beginning of the period. Refer to ASC 606-10-50-8 and
50-9.
Form 10-Q for the Period Ended September 30, 2022
Notes to Consolidated Financial Statements
5. Goodwill and Intangible Assets, Net
Goodwill, page 10
5.We note that in the third quarter of 2022, you performed a qualitative assessment to
determine whether it was more likely than not that the book value of you reporting units
exceeded the fair value and it was determined that goodwill was not impaired.  We further
note that net sales and gross billings decreased for certain of your segments including your
American Girl segment. Please tell us how you considered the factors pursuant to ASC
350-20-35-3 in determining that further impairment testing was not necessary given the
decreases. Additionally, please tell us if the fair values of each of your reporting units are
substantially in excess of their carrying values.

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 Comapany NameMattel Inc.
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Anthony DiSilvestro
Mattel Inc.
November 18, 2022
Page 3
Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 32
6.We note your discussion of gross billings and changes from period to period which is
extensive and you do not include a similar discussion of changes in the U.S. GAAP net
sales line. We note a similar discussion in your 10-K filing. We also note that you
reconcile your gross billings to the U.S. GAAP net sales amount.  Please revise to provide
a detailed discussion of significant changes in your GAAP net sales for each respective
period. Refer to Rule 303(b) and (c) of Regulation S-K. Further, consider whether it is
appropriate to include a reconciliation of gross billings to U.S. GAAP net sales if the
presentation of gross billings is meant to represent a metric instead of a non-GAAP
measure.  If it is a non-GAAP measure, please tell us how it is consistent with the
guidance in Question 100.04 of the Non-GAAP Financial Measures Compliance and
Disclosure Interpretations.
7.We note your discussion of financial results that qualitatively discuss multiple factors that
impacted changes in your financial statement line items from period to period. We note a
similar discussion in your 10-K filing. Please revise to further describe material changes
to a line item for the underlying reasons for such changes in both quantitative
and qualitative terms, including the impact of offsetting factors. Refer to Item 303(b)
of Regulation S-K.
            In closing, 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 Melissa Gilmore at (202) 551-3777 or Kevin Woody at (202) 551-3629
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing