INTCIntel

We note you have sustained goodwill impairment charges in fiscal year 2024. In addition, we note that your auditor has included Goodwill Impairment Assessment as a critical audit matter in their audit opinion. We further note significant continuing impairment indicators such as the carrying value of your net assets substantially exceeding your market capitalization at December 28, 2024.

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Please expand your critical accounting estimates disclosure to include a discussion of your estimates and assumptions pertaining to goodwill, beyond your disclosures included in Note 11 on page 83. Your disclosures should identify the number of reporting units where goodwill is allocated and tested for impairment. Additionally, indicate whether the fair value substantially exceeds book value for all reporting units at the date of your most recent test. If the fair value of any reporting unit does not substantially exceed book value, identify the reporting unit and provide the following: • the percentage by which fair value exceeded carrying value at the date of the most recent test; • the amount of goodwill allocated to the reporting unit; • a detailed description of the methods and key assumptions used and how the key assumptions were determined; • a discussion of the degree of uncertainty associated with the assumptions; and • a description of potential events and/or changes in circumstances that could reasonably be expected to negatively affect the key assumptions. Please include expanded disclosures in future filings and provide us with your proposed disclosure enhancements as part of your response.

We acknowledge the Staff’s comment requesting that we expand our critical accounting estimates disclosure in relation to the valuation methods and assumptions used in assessing goodwill for impairment, including the identification and allocation of goodwill to reporting units.

In our Q2 Form 10-Q and, to the extent applicable, in future Form 10-K filings, we will expand the discussion of this critical accounting estimate to include (i) the number of reporting units where goodwill is allocated and tested for impairment, (ii) whether the fair value substantially exceeds carrying value for all

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reporting units at the date of our most recent test, and (iii) an expanded description of the estimates and assumptions relied upon in calculating fair value, including the reconciliation we perform back to our market capitalization(s) to corroborate our conclusions. Should certain reporting units lack substantial headroom as of the goodwill impairment testing date, we will include quantitative disclosure addressing how a 1% change in the discount rate, which is the estimate most sensitive and material to our determination of fair value under the income approach, could impact our impairment conclusions for the respective reporting unit(s).

In consideration of the Staff’s comment, these changes have been reflected in the draft disclosure included above in response to Comment #1.

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We note your disclosure in the penultimate paragraph on page 69 which states "our CODMs do not regularly review or receive discrete asset information by operating segment". Given your significant investments in Intel Foundry in recent years, please clarify to us what you mean by "discrete asset information" and confirm your CODMs do not receive total asset information by segment.

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If your CODMs do not receive and review total asset information by segment, disclose the reason therefore, refer to ASC 280-10-50-26.

We acknowledge the Staff’s comment requesting additional clarification and explanation of our CODM’s review of asset information by segment. We advise the Staff that “discrete asset information” is total asset information by segment. We centrally manage all procurement, treasury, and asset management functions across the enterprise and do not maintain separate balance sheets by segment within our systems of record, nor does our CODM receive total asset information by segment for purposes of assessing segment performance and allocating resources.

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In future filings, we will state these points within our disclosures.

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If you have further comments that you would like to have addressed prior to such future filings, please let us know. If you have any questions, you may contact Scott Gawel, Corporate Vice President, Chief Accounting Officer, and Principal Accounting Officer at (408) 765-8080, or Ronald Mueller at Gibson, Dunn & Crutcher at (202) 955-8671.

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