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UPLOAD Filing

TEXAS INSTRUMENTS INC
Date: July 16, 2025 · CIK: 0000097476 · Accession: 0000000000-25-007495

Financial Reporting Regulatory Compliance Risk Disclosure

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File numbers found in text: 001-03761

Date
July 16, 2025
Author
Division of
Form
UPLOAD
Company
TEXAS INSTRUMENTS INC

Letter

Re: Texas Instruments Inc Form 10-K for the Fiscal Year Ended December 31, 2024 Response Dated June 26, 2025 File No. 001-03761 Dear Rafael Lizardi:

July 16, 2025

Rafael Lizardi Chief Financial Officer Texas Instruments Inc 12500 TI Boulevard Dallas, TX 75243

We have reviewed your June 26, 2025 response to our comment letter and have the following comments.

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our May 8, 2025 letter.

Form 10-K for the Fiscal Year Ended December 31, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 18

1. We note your response to prior comment 1. As the term "discrete tax benefits" could refer to a variety of situations giving rise to adjustments to your income taxes during the quarter, please revise your upcoming Form 10-Q to explain in reasonable detail the nature of and amounts related to each type of material discrete tax benefit that contributed to the fluctuation in your effective tax rate. Please include your proposed future disclosure with your response. July 16, 2025 Page 2 2. We note your response to prior comment 2. In your upcoming Form 10-Q, please describe the economic or industry-wide factors that affect the quality of, and potential variability of, your earnings and cash flow, providing similar transparency and granularity to the information conveyed on your earnings calls. Please include your proposed future disclosure with your response. 3. We note your response to prior comments 3 through 6 and reissue the comments. In your upcoming Form 10-Q, please provide a more informative analysis of the underlying factors contributing to material changes to your results of operations and your financial condition. In doing so, please provide similar transparency and granularity to the information conveyed on your earnings calls. Please include your proposed future disclosure with your response. 4. We note your response to prior comment 7. Please provide us with your proposed future disclosure of recently issued accounting standards you have not yet adopted.

Please contact SiSi Cheng at 202-551-5004 or Jennifer Thompson at 202-551-3737 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of
Manufacturing

Show Raw Text
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<TEXT>
 July 16, 2025

Rafael Lizardi
Chief Financial Officer
Texas Instruments Inc
12500 TI Boulevard
Dallas, TX 75243

 Re: Texas Instruments Inc
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Response Dated June 26, 2025
 File No. 001-03761
Dear Rafael Lizardi:

 We have reviewed your June 26, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our May 8,
2025 letter.

Form 10-K for the Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 18

1. We note your response to prior comment 1. As the term "discrete tax
benefits" could
 refer to a variety of situations giving rise to adjustments to your
income taxes during
 the quarter, please revise your upcoming Form 10-Q to explain in
reasonable detail
 the nature of and amounts related to each type of material discrete tax
benefit that
 contributed to the fluctuation in your effective tax rate. Please
include your proposed
 future disclosure with your response.
 July 16, 2025
Page 2
2. We note your response to prior comment 2. In your upcoming Form 10-Q,
please
 describe the economic or industry-wide factors that affect the quality
of, and potential
 variability of, your earnings and cash flow, providing similar
transparency and
 granularity to the information conveyed on your earnings calls. Please
include your
 proposed future disclosure with your response.
3. We note your response to prior comments 3 through 6 and reissue the
comments. In
 your upcoming Form 10-Q, please provide a more informative analysis of
the
 underlying factors contributing to material changes to your results of
operations and
 your financial condition. In doing so, please provide similar
transparency and
 granularity to the information conveyed on your earnings calls. Please
include your
 proposed future disclosure with your response.
4. We note your response to prior comment 7. Please provide us with your
proposed
 future disclosure of recently issued accounting standards you have not
yet adopted.

 Please contact SiSi Cheng at 202-551-5004 or Jennifer Thompson at
202-551-3737 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
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