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CORRESP

 November 24, 2021

Division of Corporation Finance

 Office of Technology

United States Securities and Exchange Commission

 100 F Street,
N.E.

 Washington, D.C. 20549

 Attn: Mitchell Austin, Staff
Attorney and Anna Abramson, Staff Attorney

Re:
 Cisco Systems, Inc.

Form 10-K for Fiscal Year Ended July 31, 2021

File No. 001-39940

Dear Mr. Austin and Ms. Abramson:

 On
behalf of Cisco Systems, Inc., a Delaware corporation (the “Company”), set forth below is the Company’s response to the comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) as set forth in the Staff’s comment letter, dated October 28, 2021, which was in response to the Staff’s initial comment letter, dated September 15, 2021.

For ease of reference, the headings and numbers of responses set forth below correspond to the headings and numbers in the Staff’s most
recent comments, and we have also set forth below, in italics, the text of the Staff’s most recent comments prior to the response.

 Form 10-K for Fiscal Year Ended July 31, 2021

 Risk Factors, page 13

1.
 Your response to prior comment 2 states that you actively monitor and assess your material litigation risks
in advance of each filing and that your assessments to date have concluded that you are not subject to material litigation risks related to climate change. Please tell us about any litigation risks related to climate change that were included in
your most recent assessment and explain how you analyzed the materiality of these risks.

 Cisco Systems, Inc.

170 West Tasman Drive

 San Jose, CA
95134-1706

 Phone: 408 526-4000

Fax: 408 526-4100

www.cisco.com

 Response:

When assessing whether disclosure is required under Item 105 of Regulation S-K, the Company assesses
the material factors that make an investment in the Company speculative or risky. Additionally, as it relates to climate change-related disclosure, the Company’s assessment includes the considerations outlined in the Commission’s
Guidance Regarding Disclosure Related to Climate Change (Securities Act Rel. 33-9106, Feb. 2, 2010) (“2010 Guidance”).

As noted in the Company’s response to the Staff’s prior comment 2, the Company actively monitors and assesses its litigation risks
in advance of each relevant filing with the Commission to determine whether it has material litigation risks that should be considered for disclosure. To clarify the Company’s previous response for the Staff, the Company’s assessment, to
date, is that it has not experienced any actual or threatened litigation against the Company related to climate change, and is not otherwise aware of any litigation risk facing the Company related to climate change. As such, the result of such
assessments to date is that the Company is not subject to litigation risks related to climate change, material or otherwise. Accordingly, the Company believes risk factor disclosure on this topic is not required at this time.

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 30

2.
 Your response to prior comment 3 refers to pending and existing climate change-related legislation,
regulations, or international accords. Explain in greater detail how you determined whether these laws and regulations are reasonably likely to have a material effect on you and how you assessed your compliance with any requirements
thereunder. Also, tell us how you considered providing disclosure regarding the difficulties involved in assessing the timing and effect of pending climate-related laws or regulations.

Response:

 When assessing whether
disclosure is required under Item 303 of Regulation S-K, the Company assesses whether a trend, demand, commitment, event or uncertainty is both presently known to management and reasonably likely to have a
material impact on the Company’s financial condition or results of operations. Additionally, as it relates to climate change-related disclosure, the Company’s assessment includes the considerations outlined in the 2010 Guidance.

To assist the Staff with context specific to the Company, and as also described in greater detail in the Introduction to the Company’s
response to the Staff’s initial comments, the Company has been involved with environmental sustainability and reduction of its greenhouse gas (“GHG”) emissions for many years—since 2006, in fact. This means that the Company has,
for over 15 years, voluntarily gathered and reported climate change-related data to measure commitments and report its progress. As described in greater detail below, the Company believes that the

 Cisco Systems, Inc.

170 West Tasman Drive

 San Jose, CA
95134-1706

 Phone: 408 526-4000

Fax: 408 526-4100

 www.cisco.com

requirements of each current environmental-related or pending climate change-related law and/or regulation, as presently enacted or drafted, as applicable, incurs no more than insignificant
incremental cost to the Company related to its costs for existing compliance programs or voluntary climate change-related data gathering and reporting efforts. To date, the Company has concluded that the costs related to compliance with each
existing environmental-related or pending climate change-related law and/or regulation have not, nor does the Company believe that they are reasonably likely to, result in a material impact to the Company’s financial condition or results of
operations.

 In undertaking its assessment with respect to pending climate change-related laws and/or regulations known to management and
whether such laws and/or regulations would be reasonably likely to have a material impact on the Company’s financial condition or results of operations, the Company compares what the costs are or are anticipated to be in order to comply with
the requirements of such laws and/or regulations and compares such costs to the Company’s consolidated financial statements for the relevant period and also assesses whether compliance with such laws and/or regulations would require a
significant change to the Company’s existing operations or strategy. When comparing the Company’s existing compliance programs and existing climate change-related data gathering and reporting processes to the requirements of the pending
climate change-related laws and/or regulations presently known to management, the Company believes that compliance with such laws and/or regulations would require insignificant adjustments to existing programs and processes that the Company already
has in place for its compliance programs and/or its voluntary climate change-related data gathering and reporting. Additionally, the Company considers anticipated costs related to compliance with pending climate change-related laws and/or
regulations and assesses whether such costs are reasonably likely to have a material impact on the Company’s financial condition or results of operations. To date, the actual costs and impacts of the Company’s compliance with pending
climate change-related laws and/or regulations have not been, and the expected costs are not anticipated to be, material to the Company’s financial condition or results of operations, as such, the Company believes disclosure is not required at
this time.

 Furthermore, in terms of disclosure considerations with respect to the timing or effect of any pending climate change-related
laws and/or regulations, the Company is unaware of any such law or regulation the timing or effect of which would cause the Company significant cost to comply with, when comparing such actual or anticipated costs to the Company’s consolidated
financial statements. Additionally, as described above, the Company already has internal processes for data gathering and reporting related to its voluntary climate change reporting. The pending climate change-related laws and/or regulations that
the Company anticipates being subject to will generally require the Company to report data it either already voluntarily collects and reports or can easily collect or report with insignificant adjustments to its already existing processes and, as
such, the Company notes that the timing or effect of pending climate change-related laws and/or regulations

 Cisco Systems, Inc.

170 West Tasman Drive

 San Jose, CA
95134-1706

 Phone: 408 526-4000

Fax: 408 526-4100

 www.cisco.com

would require no significant adjustment to the Company’s existing operations or strategy. Because the Company does not anticipate any significant costs or changes required to its operations
or strategy, the Company does not believe the timing or effect of pending climate-related laws or regulations is reasonably likely to have a material effect on the Company’s financial condition or results of operations, as such, the Company
believes disclosure is not required at this time.

 The Company anticipates being subject to future climate change-related laws and/or
regulations as countries begin to set their own climate-related commitments. As previously noted in the Company’s response to the Staff’s prior comment 3, the Company cannot predict whether new laws or regulations related to climate change
that may be proposed and implemented in the future could impose material costs or otherwise materially impact its business, but this remains a risk. The Company discloses this risk in “Risk Factors – Risks Related to Cybersecurity and
Regulations – Our business, operating results and financial condition could be materially harmed by regulatory uncertainty applicable to our products and services” and believes that placement of the disclosure of potential future risk in
“Risk Factors” is the most suitable location in its Form 10-K filing with the Commission.

3.
 Your response to prior comment 4 states that your climate-related projects have not required material
capital expenditures, individually or in the aggregate, or otherwise been material. In order to better understand your response, please tell us about your capital expenditures related to climate-related projects (including quantification of amounts
incurred) and explain how you assessed the materiality of these expenditures. In addition, please tell us more about how you considered providing disclosure quantifying the estimated costs of reaching net zero greenhouse gas emissions, which you
discuss in the introduction of your response, and explain how you analyzed the materiality of these costs.

 Response:

As noted in the Company’s response to the Staff’s initial comment 4 and as discussed in further detail below, to date, the
climate-related projects included in the Company’s Corporate Social Responsibility (“CSR”) reports have not required material capital expenditures, individually or in the aggregate, or otherwise been material to the Company, when
comparing such costs, individually or in the aggregate, to the Company’s consolidated financial statements for the relevant period.

As described in the Company’s 2020 CSR report, the Company implemented a variety of climate-related projects categorized in two main
categories: energy efficiency projects and renewable energy procurement projects. Between fiscal year 2016 and fiscal year 2020, the Company implemented 443 energy efficiency projects with an aggregate implementation cost of approximately
$55 million, which cost the Company does not believe was significant when comparing such costs to the aggregate capital expenditures of $4.6 billion between fiscal year 2016

 Cisco Systems, Inc.

170 West Tasman Drive

 San Jose, CA
95134-1706

 Phone: 408 526-4000

Fax: 408 526-4100

 www.cisco.com

and fiscal year 2020. Notably, the implementation costs of such projects were fully recouped by the Company, as the projects provided the Company a return on its investment as a result of the
energy efficiencies created. Examples of the energy efficiency projects include improving airflow in the Company’s laboratories, installing LED lighting in the Company’s buildings, and optimizing the Company’s mechanical equipment.
The Company’s renewable energy procurement projects are designed to reduce the Company’s reliance on energy grid power across its global operations. In fiscal year 2020, the Company invested an aggregate of approximately $8.7 million
across 44 renewable energy procurement projects related to its global real estate portfolio, which cost the Company does not believe was significant, when comparing such costs to the Company’s total costs and expenses of $35.7 billion for
fiscal year 2020 or otherwise when comparing such costs to the Company’s consolidated financial statements for the relevant period. Additionally, the Company notes that the renewable energy procurement projects have also provided the Company a
return on its investment, and the Company expects to fully recoup its investment in such projects over the course of the next few years.

In assessing the materiality of such climate-related project costs, the Company determines whether the related costs of such projects are
reasonably likely to result in a material impact to the Company’s financial condition or results of operations. To date, the Company has not incurred any significant costs, individually or in the aggregate, for its climate-related projects and
does not believe any currently planned projects will incur significant costs, individually or in the aggregate. For these reasons, the Company believes that the costs related to its climate-related projects have not and are not reasonably likely to
result in a material impact to the Company’s financial condition or results of operations, as such, the Company believes disclosure is not required at this time.

With respect to the Company’s net zero commitments, the Company considers disclosure of a commitment pursuant to Item 303 of Regulation S-K and the 2010 Guidance when it believes that a cost of a commitment is reasonably likely to result in a material impact to the Company’s financial condition or results of operations. In assessing whether
disclosure is required for the Company’s net zero commitments, the Company considers what the actual costs are to date and what the expected costs are reasonably likely to be in the future and whether such costs have or are reasonably likely to
result in a material impact to the Company’s financial condition or results of operations. What future costs are reasonably likely to be includes an assessment of the Company’s estimates and assumptions that underly the commitments, taking
into consideration how the Company has previously performed against related estimates and assumptions, and how those estimates and assumptions are performing as time goes on as the Company continues to assess its commitments.

 Cisco Systems, Inc.

170 West Tasman Drive

 San Jose, CA
95134-1706

 Phone: 408 526-4000

Fax: 408 526-4100

 www.cisco.com

 The Company notes that, to date, it has had a long track record of success with its estimates
and assumptions related to climate change goals. Over the last decade, the Company has been setting 5-year goals related to its climate change initiatives. For example, the Company met its previous 5-year Scope 1 and 2-related goal one year early, in fiscal year 2021, and it also met its previous 5-year goal of using energy
generated from renewable sources one year early, also in fiscal year 2021, and in each case, the Company believes the underlying estimates and assumptions related to these goals were accurate. These examples are indicative of the Company’s
history, to date, of success in achieving its climate change-related goals, with costs of such goals well within the Company’s estimates it had budgeted for such goals. Furthermore, this track record of success has helped to inform the Company
as to the appropriate timing of achieving its net zero commitments and, while the Company notes that past accuracy of its estimates and assumptions does not guarantee future accuracy as external fact