SecProbe.io

June 3, 201 3

Via E -mail
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 March 2 , 201 3
Filed March 28, 2013
File No. 0-29898

Dear Mr. Bidulka:

We have reviewed your filing and have the following comments.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your documents.  In some of our comments, we may  ask you to
provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing  or by
advising us when you will provide the requested response.   If you do not believe our comments
apply to your facts and circumstances or do not believe an amendment is appropriate, please tell
us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have ad ditional comments.

Form 40 -F for the Fiscal Year Ended March 2, 2013

Exhibit 1.2

Financial Statements
Note 10. Commitments and Contingencies
(c) Litigation, page 36

1. In light of the significant number of lawsuits identified under Legal Proceedings, it  is
unclear why you have not provided in an audited footnote any specific disclosure
concerning the details of the suits, your assessment of the reasonably possible resolution
of the suits, or your accounting for them.  You are required pursuant to ASC par agraphs
450-20-50-3 and 50 -4 to provide disclosure of each contingency where there is a

Mr. Brian Bidulka
Research In Motion Limited
June 3, 2013
Page 2

 reasonable possibility of loss, including the specific nature of the contingency and an
estimate of the possible loss or range of loss, or a statement that such an esti mate cannot
be made.  Please revise your footnote disclosure accordingly or advise us.

2. Your policy disclosure in the second paragraph of this note states that “[w]here it is
considered probable for a material exposure to result and where the amount of the  claim
is quantifiable, provisions for loss are made based upon management’s assessment of the
likely outcome.”  Note that ASC 450 -20-25-2(a) does not provide a materiality condition
for loss recognition.  Also, the ability to quantify the amount of the cl aim appears to be a
higher threshold than being able to reasonably estimate the amount of loss, the condition
necessary for accrual under paragraph ASC 450 -20-25-2(b).  Please refer to this guidance
and the guidance found in paragraph ASC 450 -20-25-5, and revise your policy
accordingly.

3. Furthermore, we note it is your stated policy to not provide for claims that are unlikely to
result in a significant loss or claims where the amount of the loss cannot be reasonably
estimated.  The likelihood of a significa nt loss is not a condition for loss recognition
under generally accepted accounting principles.  Also, the requirement that the amount of
loss can be reasonably estimated should not delay accrual of a loss until only a single
amount can be reasonably estim ated.  Refer to the guidance in 450 -20-30-1 and revise
your policy accordingly, and advise us.

4. Please tell us your estimated range of reasonably possible loss, in aggregate for all
contingencies, in excess of what has been accrued in your financial statem ents.

Exhibit 1.3

Management’s Discussion and Analysis of Financial Condition and Results of Operations for the
Three Months and Fiscal Year Ended March 2, 1013

Sources of Revenue, pages 7 and 8

5. We note your 2013 fourth quarter change in how you determine your total subscriber
account base.  Please tell us why you are not also presenting the total subscriber account
base that only includes subscribers that generate service revenues.  It appears this
information is useful to investors since it has a direct relationship with your service
revenues.  We note your disclosures on page 8 and the numeric subscriber base
disclosures on pages 9 and 18 of Exhibit 1.1.

6. In regard to the above comment, we note on page 18 you disclose the company has a
global su bscriber base of more than 76 million “users” as of the end of fiscal 2013.  Since
this metric includes accounts that are not active, it appears identifying it as “users” rather
than subscriber accounts may confuse what is in fact being disclosed.  Please advise us

Mr. Brian Bidulka
Research In Motion Limited
June 3, 2013
Page 3

 and explain to us your consideration of how to clarify this disclosure in the future, if
necessary.

*    *    *    *

Please file all correspondence over EDGAR.  We urge all persons who are responsible
for the accuracy and adequacy of the disclo sure 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 disclo sure, 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 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 S.
Littlepage, Accountant Branch Chief,  at (202) 551 -3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact  me at (202) 551 -3810
with any other questions.

Sincerely,

/s/ Robert S. Littlepage  for

Larry Spirgel
Assistant Director