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CORRESP
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CORRESP

 December 12, 2022

VIA EDGAR

 Ms. Jenifer Gallagher

Mr. Karl Hiller

 United States Securities and Exchange
Commission

 Division of Corporate Finance, Office of Trade & Services

100 F Street, NE

 Washington, D.C. 20549

Re:
 Pixelworks, Inc.

Form 10-K for the Fiscal Year ended December 31, 2021

Filed March 9, 2022

File No. 000-30269

Dear Ms. Jenifer Gallagher and Mr. Karl Hiller:

Pixelworks, Inc. (the “Company”) provides the following information in response to the comments contained in the correspondence of the staff (the
“Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated November 7, 2022, relating to the aforementioned Form 10-K. For reference purposes, the text
of your letter dated November 7, 2022, has been reproduced herein (in bold), with the Company’s response below each numbered comment.

Form 10-K for the Fiscal Year ended December 31, 2021

Risk Factors

 Company Specific Risks, page 18

1.
 We note that you have proposed some disclosures to address the China Based Issuer sample comments referenced
in prior comment two, although some applicable disclosure points are not clearly represented in your intended disclosures.

Please address the specific language utilized for each disclosure point among sample comments 2, 4, 5, 7, 8, 9, 14 and 15, by either
proposing incremental disclosures, identifying disclosures that you believe are specifically responsive, or explaining to us why you believe a disclosure point is inapplicable.

 Please clarify the manner by which disclosures responsive to these concerns will appear
within the Risk Factors section that begins on page 17 and be represented among the list of Risk Factors on page 2, where we believe that you should segregate and differentiate risks associated with having operations in China.

Response:

 The specific language the Company plans to use
for each disclosure point from sample comments 2, 4, 5, 7, 8, 9, 14 and 15, or the fact that the Company believes such disclosure point to be inapplicable, is set forth on Appendix A to this response letter.

The Company respectfully advises the Staff that it intends to segregate and differentiate its risks associated with having operations in China by including
the risk factor language indicated in the chart attached on Appendix A within the Risk Factors section in a new section entitled “Risks Related to Our Operations in China” and will further represent this disclosure in the Summary Risk
Factor section of its next annual report on Form 10-K. The Company further advises the Staff that the Company’s risk factors previously listed under the Section “Risks Related to Our Strategic Plan
and STAR Market Listing” will also be included within this new category of risk factors.

 Management’s Discussion and Analysis of
Financial Condition and Results of Operation Overview, page 40

2.
 We note your response to prior comment three indicating that you intend to provide disclosure to clarify
whether the pandemic and shortages in the global semiconductor business have adversely effected [sic] your key suppliers and manufacturing partners, how these may have also effected [sic] your outlook and business goals, and to discuss the extent to
which your results of operations and capital resources have been impacted.

 You were also asked to discuss any
efforts that you have undertaken to mitigate these concerns and any uncertainties arising from those efforts or which otherwise prevail over your ability to maintain or ensure product quality, reliability of product development and order fulfillment
processes, or to obtain regulatory approvals.

 Please submit the specific disclosures that you propose to address and clarify these
concerns. We reissue prior comment three.

 2

 Response:

The Company’s planned disclosures to address and clarify the concerns raised by the Staff in Comment #2 are set forth below. The Company also respectfully
advises the Staff that these concerns have not affected the Company’s ability to maintain or ensure product quality, reliability of product development and order fulfillment processes, or to obtain regulatory approvals.

Revised disclosure:

 In March 2020, the World
Health Organization declared the COVID-19 outbreak a pandemic, and the virus continues to exist in areas where we operate and sell our products and services. In response to the
COVID-19 pandemic, many state governments in the U.S. and abroad issued restrictive orders, including “shelter in place” or “stay at home” orders, that have restricted their residents from
leaving their homes or returning to work. Since March 2022, various cities in China have imposed lockdowns in response to China’s “zero-COVID” policy, leading to weaker consumer demand which has
had, and we anticipate may continue to have, an adverse impact on China’s economy, on our customers and on our business. For example, demand in our mobile market was down during the second half of 2022, which we believe was largely attributable
to the imposed lockdowns in China. More recently, China announced a relaxation of its “zero-COVID” policies, which increases the risk of large outbreaks of
COVID-19 in China, which could have an adverse impact on China’s economy, on our customers and on our business.

The spread of COVID-19 has caused us to modify our business practices, including implementing
work-from-home policies and limiting travel by our employees. Our Shanghai and Shenzhen offices have been alternating between full in-person staffing and remote staffing as local ordinances continue to
change in response to new outbreaks. Outbreaks and various strict actions by the Chinese government in response have impacted and will continue to impact the ability of our sales team in China to make
in-person sales calls to current and potential customers at the same volume as they did prior to the outbreak of the pandemic. However, our offices and supply chain partners in Taiwan, and our offices in Japan
and North America are fully operational. Additionally, the Company has, in the past and may continue, in the future, to take certain mitigation measures. For example, and as previously reported, in 2020 the Company implemented several cost-saving
measures, including reductions in executive salaries, elimination of bonus programs, and hiring freezes. Since then, the Company has carefully monitored its costs in light of the uncertainty caused by the pandemic.

COVID-19 has, and may continue to, negatively affect the operations of our suppliers and
customers, as their own workforces and operations are disrupted by the pandemic, which could result in the interruption of our distribution system, temporary or long-term disruption in our supply chains, or delays in the delivery of our product.
While the Company experienced some mild supply chain disruption in the first quarter of 2022, to date, these concerns do not materially affect the Company’s outlook or business goals, and the Company is not experiencing disruption in its supply
chain or delays in in the delivery of its products.

 3

 While we expect the impacts of COVID-19 to be
temporary, the disruptions caused by the virus has negatively affected our revenue and results of operations since its outbreak.

 The
future impact of the pandemic on our business, as well as the business of our suppliers and customers, and the additional measures that may be needed in response to it, including any new cost-saving measures, will depend on many factors beyond our
control and knowledge. We will continually monitor the situation to determine what actions may be necessary or appropriate to address the impact of the pandemic, which may include actions mandated or recommended by federal, state or local
authorities.

 Results of Operations, page 42

3.
 We note your response to prior comment four including sample disclosure based on the results for 2021
compared to 2020, indicating that revenues for the Mobile and Projector key market segments increased to $19.4 million and $29.7 million, respectively, and together represent about 97% of IC sales revenues for 2021.

 Given the revisions proposed in response to prior comment one, we understand that IC sales to the Video Delivery
market segment represents the other 3%; and that the balance of revenues to this market segment plus those to the Cinema market segment account for all of the service revenues. Please clarify whether this is correct.

Please include volumetric measures of products sold, disclose the extent to which changes in revenues for the key market segments are
attributable to changes in volumes and changes in prices, and discuss the reasons for material changes as previously requested.

Provide us with a schedule including volumetric metrics of the key products sold in each key market segment, along with the revenues
ascribed for each quarter covered by your annual and subsequent interim reports, reconciled to the consolidated amounts, along with an explanation of how your have considered these details for disclosure.

Response:

 The Company confirms that 100% of its revenue
is derived from (1) sales of integrated circuits (IC Sales) into the mobile, projector and video delivery markets and (2) engineering services, license revenue and other in the mobile, video delivery and cinema markets.

 4

 With respect to the Staff’s request for additional disclosure in its results of operations, the Company
would note that it has considered the requirements of Item 303(a) of Regulation S-K which calls for the following disclosure, with materiality as the overarching principle:

•

 Material information relevant to an assessment of the financial condition and results of operations of the
registrant

•

 Material events and uncertainties known to management that are reasonably likely to cause reported financial
information not to be indicative of future operating results or of future financial condition

•

 The material financial and statistical data that the registrant believes will enhance a reader’s
understanding of the registrant’s financial condition, cash flows and other changes in financial condition, and results of operations

Additionally, the Company has considered the requirements of Item 303(b) to describe the significant components of revenue or expenses that, in the
registrant’s judgment, would be material to an understanding of the registrant’s results of operations, as well as the requirement to describe, where there are material changes in line items period to period, the underlying reasons for
these changes in quantitative and qualitative terms. Finally, the Company has also considered Item 303(b)(2) which states that if the statement of comprehensive income presents material changes from period to period in net sales or revenue, if
applicable, describe the extent to which such changes are attributable to changes in prices or to changes in the volume or amount of goods or services being sold or to the introduction of new products or services.

After considering these requirements in detail, including the general focus on materiality, the Company’s revised disclosure, which is presented using
information for the three and nine-month period ended September 30, 2022, is set forth below.

 The Company believes it is providing quantitative
information necessary for an understanding of the Company’s results of operations from management’s perspective by: (a) providing a revenue breakdown between the Company’s revenue categories of IC Sales and Engineering services,
license revenue and other, and (b) within IC Sales, including additional quantitative information regarding the amount and percentage change of revenue within the three applicable target markets. The Company recognizes the Staff has requested
that the Company include a “volumetric measure” of products sold, such as number of units sold within each target market, but does not believe such disclosure is either required by Item 303 of Regulation
S-K, nor material to an understanding of the Company’s results of operations.

 The Company believes it is
providing the qualitative information necessary for an understanding of the Company’s results of operations from management’s perspective by providing additional detail about the underlying reasons for any material changes within IC Sales,
by target market, as well as noting, where applicable, whether the changes, if material, were attributable to changes in prices or to changes in volume of goods/services sold, each, if applicable.

 5

 Revised disclosure:

Revenue, net

 Net revenue for the three and nine months
ended September 30, 2022 and 2021, was as follows (dollars in thousands):

Three Months Ended September 30,

Nine Months Ended September 30,

2022

2021

% Change

2022

2021

% Change

 Revenue, net

$
17,552

$
15,196

16
%

$
53,258

$
38,516

38
%

 Revenue recorded in the third quarter of 2022 consisted of $17.2 million in revenue from the sale of integrated circuit
(“IC”) products and $0.4 million in revenue related to engineering services, license revenue and other. Revenue recorded in the third quarter of 2021 consisted of $14.3 million in revenue from the sale of IC products and
$0.8 million in revenue related to engineering services, license revenue and other.

 Revenue from the sale of IC products increased 20% compared to
the third quarter of 2021, due to an increase in units sold and a change in product mix. Specifically:

•

 Sales into the mobile market increased $1.6 million or 36%, due to a change in product mix as more customers
transitioned to newer generation product offerings

•

 Sales into the projector market increased $0.9 million or 10%, due to an increase in units sold due to
higher customer demand

•

 Sales into the video delivery market increased $0.4 million or 38%, primarily due to a change in product mix

 Revenue from the sale of IC products increased 45% compared to the first nine months of 2021, due to an increase in units sold and a
change in product mix. Specifically:

•

 Sales into the mobile market increased $6.9 million or 59%, primarily due to an increase in units sold
driven by increased customer demand and by a change in product mix as more customers transitioned to newer generation product offerings

•

 Sales into the projector market increased $5.7 million or 26%, primarily due to a change in product mix

•

 Sales into the video delivery market increased $3.7 million or 132%, primarily due to an increase in units
sold and also due a change in product mix

 6

 Financial Statements

Note 7—Revenue Recognition, page 69

4.
 We understand from your response to prior comment five that you would rather not disclose IC Sales for the
four key market segments identified on page 8, notwithstanding the criteria in FASB ASC 606-10-55-89 through 55-91.

 However, as previously noted, you routinely discuss revenues in terms of
your target markets, to include disclosures in investor presentations, earnings releases, conference calls, and MD&A. In your response to prior comment four you include draft revisions that specify revenues for the Mobile and Projector markets,
and in your response to prior comment six, you confirm that your chief operating decision maker is routinely provided a breakdown of historical revenue and forecasted revenue for these target markets.

We also note that in your August 2022 Investor Presentation, you identify the Home and Enterprise markets as “Mature business lines
[that] fund Mobile & [Cinema’s] TrueCut growth initiatives” and indicate that growth in the Mobile segment is “contributing increased portion of total revenue mix” from 36% in 2021 to 39% in the second quarter of 2022.
You identify and characterize drivers of the Mobile segment as being “Fueled by massive platform and content ecosystems.” You also disclose the revenue mix for Mobile/Cinema’s TrueCut and Projector/Video Delivery for the last four