SecProbe.io

June 20, 2014
Via Email
Mr. James Yersh
Chief Financial Officer
BlackBerry Limited
2200 University Avenue East
Waterloo, Ontario
Canada, N2 K 0A7

Re: BlackBerry Limited
Form 40-F for the F iscal Year E nded March 1, 201 4
Filed March 28, 2014
File No. 000-29898

Dear Mr. Yersh :

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 this letter within ten business days by providing the requested
informat ion or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these  comments , we may
have additional comments.

Form 40 -F for the Fiscal Year Ended March 1, 2014

Exhibit 1.2

Financial Statements

Consolidated Statements of Operations

1. We note that your hardware and other cost of sales included $782 million inventory
write -down o f your Blackberry Z10 devices and supply commitments and $1.6 billion
inventory  write -down  of your Blackberry 10 devices .  Please tell us why such write -
downs were not separately presented on the face of the financial statement  pursuant to
ASC 330 -10-50-2 and ASC 330 -10-50-5.

Mr. James Yersh
BlackBerry Limited
June 20, 2014
Page 2

 Note 1. Critical Accounting Estimates

Revenue Recognition, page 10

2. Please refer to the last sentence.  Tell us in detail why the revenues from your Blackberry
10 and 7 devices in certain regions are recognized when such devices sel l through to the
end customers.  It appears you are referring to hardware products revenues with price
protection provisions.  If so, the disclosure should be clarified to inform an investor that
you are referring to the price protection provisions previou sly disclosed.  In addition, tell
us why this revenue recognition policy is limited to certain regions.  If you expect this
trend to significantly impact your future financial condition and results of operations,
please provide a discussion of such impact in your MD&A.

Note  3.  Cash, Cash Equivalents and Investments, page 12

3. Please tell us how you are accounting for your securities lending arrangements including
the related collateral.  Refer to your basis in the accounting literature.

Exhibit 1.3

Management’s Discussion and Analysis of Financial Condition and Results of Operations Fiscal
year ended March 1, 2014 compared to fiscal year ended March 2, 1013

Accounting Policies and Critical Accounting Estimates

Critical Accounting Estimates, page 11

4. We note that significant judgment is applied to determine whether shipments of your
devices have met your revenue recognition criteria.  Please expand to discuss your
methods, assumptions and estimates used in your recognition of hardware devices
revenues.

Service Revenue, pages 18

5. We note that you expect your future service revenues to decrease significantly due to the
reduction in SAF.  Please disclose the amount and percentage of SAF included in service
revenues for fiscal 2014 as compared to fiscal 2013.

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 all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Mr. James Yersh
BlackBerry Limited
June 20, 2014
Page 3

             In responding to our comments, please provide  a writ ten 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 Joseph
Kempf , Senior Staff Accountant, a t 202-551-3352 if you have questions regarding comments on
the financial statements and related matters.  Please contact Paul Fischer , Attorney -Advisor, at
202-551-3415 or me at  202-551-3810  with any other questions.

Sincerely,

 /s/ Robert S. Littlepage, for

Larry Spirgel
Assistant Director