SecProbe.io

April 20, 2011

U.S. Mail and Fax (519-888-7884)
Mr. Brian Bidulka Chief Financial Officer Research In Motion Limited 295 Phillip Street Waterloo, Ontario Canada, N2L 3W8
Re: Research In Motion Limited
Form 40-F for the fiscal year ended February 26, 2011 Filed March 29, 2011 File No. 0-29898

Dear Mr. Bidulka:

 We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other portions of your documents.
 Please provide us with
the requested information so we may better understand your disclosure.

Please respond to this letter within te n 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 circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.               Form 40-F for the Year Ended February 26, 2011

 Exhibit 1.2

Note 10(c) Litigation, page 34

1. Please tell us why additional disclosures of  the amount accrued and/or estimate of the
reasonable possible loss in excess of the amount accrued are not required under ASC
450-20-50.
 Exhibit 1.3

Results of Operations – Fiscal 2011 Co mpared to Fiscal 2010 and Fiscal 2009
Revenue, page 17

2. Based on your segment disclosures on page 44 of Exhibit 1.2, we note that your current
U.S. revenues have decreased 9.2% from 2010 and your current U.S. revenues represent

Mr. Brian Bidulka
Research In Motion Limited April 20, 2011 Page 2

39.3% of your 2011 total revenues as compared to 57.7% of 2010 total revenues.  Please
tell us if the smartphones of your competito rs (e.g., iPhone and Android) materially
impacted your current U.S. revenues.  If s o, tell us why your discussion did not discuss
this factor and whether you expect this trend to continue or ch ange.  In addition, tell us if
you expect the smartphones of your competitors to materially impact your future business
in other countries.

*    *    *    *
 Please file all correspondence over EDGAR.  We urge all persons who are responsible
for the accuracy and adequacy of the disclosure 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 a ll facts relating to a
company’s disclosure, 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 accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact Dean Suehiro, Senior Sta ff Accountant, at (202) 551-3384 or Carlos
Pacho, Senior Assistant Chief Accountant, at (202) 551-3385 if you have questions regarding
comments on the financial statements and relate d matters.  Please contact me at (202) 551-3810
with any other questions.
Sincerely,    Larry Spirgel Assistant Director