SecProbe.io

Mail Stop 3720

October 23, 2015

Cynthia L. Poehlman
Chief Financial  Officer
Parkervision, Inc.
7915 Baymeadows Way, Suite 400
Jacksonville, Florida 32256

Re: Parkervision, Inc.
Form 10 -K for Fiscal Year Ended December 31, 2014
Filed March 16, 2015
  File No. 000 -22904

Dear Ms . Poehlman :

We have reviewed your filing and have the following comments.  Please comply with the
following comments in future filings.  Confirm in writing  that you will do so and explain to us
how you intend to comply.  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 th e 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.

1.  We note your statement that since 2005 your technologies have generated no royalty or
product revenues.  Please revise to provide additional background information to help
investors understand the reasons for this absence of revenues, especially in the lig ht of
your large R&D expenditures.  For example, provide a brief history of the company,
highlighting, for example, when your principal products were first developed and
marketed, and how the decision to file a patent claim against Qualcomm came about.
Clarify the extent to which the company pursued other means of revenues during the
pendency of that claim.

2. You state that the litigation investment firm 1624 PV, LLC will likely receive a “portion
of our proceeds” and that their compensation is subject to a maximum.  In light of the
importance of such litigation proceeds to your current business plan, please provide
greater clarity regarding the impact such compensation will have on whatever proceeds
you may receive from future litigation.   You need not di sclose an exact amount of or

Cynthia L. Poehlman
Parkervision, Inc.
October 23, 2015
Page 2

 percentage for determining such compensation, but may instead, for example, provide a
range or formula.

We urge all persons who are responsible for the accuracy and adequacy of the disc losure
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 company and its management are
in possession of all facts relating to a company’s disc losure, 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 company
acknowledging that:

 the company is responsible for the adequacy and accura cy 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.

You may contact Dean Suehiro, Senior Staff Accountant , at 202-551-3384 or Robert
Littlepage, Accountant Branch Chief,  at 202-551-3361 if you hav e any questions regarding the
financial statements and related matters.  Please contact  Gregory Dundas, Attorney -Advisor, at
(202) 551 -3436, Celeste M. Murphy, Legal Branch Chief, at (202) 551 -3257, or me at (202) 551 -
3810 with any other questions.

Sincere ly,

 /s/ Celeste M. Murphy for

 Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications