SecProbe.io

May 15, 2012

Via E -mail
Mr. Kevin P. March
Senior Vice President, Chief Financial Officer  and Chief Accounting Officer
Texas Instruments Incorporated
12500 TI Boulevard, P.O. Box 660199
Dallas, Texas  75266 -0199

Re: Texas Instruments Incorporated
  Form 10-K for the Fiscal Year Ended  December  31, 201 1
Filed  February 24, 2012
Response Letter Dated April 27, 2012
  File No.  1-3761

Dear Mr.  March :

We have reviewed your response  letter  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 ten 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 circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments, we m ay
have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 20 11

1. Please expand your response to prior comments 6 and 7 to clarify how you determined
the products and product lines within your segments are “groups of similar products” for
purposes of Regulation S -K Item 101(c)(1)(i) given that your disclosures appear to
indicate such product lines perform different functions and have different life cycles.

Mr. Kevin P. March
Texas Instruments Incorporated
May 15, 2012
Page 2

 Notes to Financial statements, page 6

Note 17 – Segment and geographic are a data, page 36

2. We note your response to prior comment 4 that although depreciation expense is included
in the measure of segment profit, you are unable to determine the specific amount of
depreciation expense allocated to each segment as required by FASB  ASC 280 -10-50-22.
Considering this fact, and in order to provide investors with a better understanding of
your allocations, please revise future filings to disclose the reasons why you are unable to
provide the amount of depreciation expense allocated to each segment.

You may contact Gary Newberry at (202) 551 -3761  or me at (202) 551 -3643 if you have
questions regarding comments on the financial statements and related matters.  Please contact
Mary Beth Breslin  at (202) 551-3625 or Geoffrey Kruczek  at (202) 551 -3641  if you have
questions on other comments.  In this regard, do not hesitate to contact Martin James, Senior
Assistant Chief Accountant at (202) 551 -3671.

        Sincerely,

        /s/ Kevin L. Vaughn

        Kevin L. Vaughn
        Accounting Branch Chie f