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United States securities and exchange commission logo
August 4, 2022
Kirsten Spears
Chief Financial Officer
Broadcom Inc.
1320 Ridder Park Drive
San Jose, CA 95131
Re: Broadcom Inc.
Form 10-K for
Fiscal Year Ended October 31, 2021
Response Dated July
11, 2022
File No. 001-38449
Dear Ms. Spears:
We have reviewed your July 11, 2022 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
June 24, 2022 letter.
Response Dated July 11, 2022
Risk Factors, page 13
1. Your response to
comment 2 states that transition risks related to climate change were not
identified as being
reasonably expected to have a material effect on your business,
operating results, or
financial condition in connection. Please explain how you concluded
on the materiality of
the effects of climate change and determined that disclosure was not
necessary.
Kirsten Spears
FirstName LastNameKirsten Spears
Broadcom Inc.
Comapany
August NameBroadcom Inc.
4, 2022
August
Page 2 4, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations , page
35
2. Your response to comment 4 refers to capital expenditures for
climate-related projects at
your Fort Collins, Colorado facility. Please tell us about and
quantify climate-related
projects at your other facilities for the periods covered by your Form
10-K.
3. As your response to prior comment 6 does not provide all of the
requested information, it
is reissued in part. Please include the quantification requested by
our comment (including
with regards to the cost of insurance) on an aggregate basis, rather
than as a quantitative
example, for each of the periods covered by your Form 10-K and explain
whether
increased amounts are expected in future periods.
4. We note your response to prior comment 6. Please further explain how
you considered
providing disclosure regarding the physical impacts of climate change,
such as effects on
the severity of weather, as it appears that you may be vulnerable to
severe weather or
climate-related events. For example, your response notes the wildfires
in Colorado in
fiscal 2020 and disclosure on page 22 of your Form 10-K states that
many of your
facilities, and those of your contract manufacturers and suppliers,
are located in California
and the Pacific Rim region which have severe weather activity. We also
note from your
ESG Report that climate change is creating serious issues for the
Colorado and western
U.S. regions and that you have response plans for various
situations including climate-
related weather events, like wildfires, hurricanes, flooding and
blizzards. In addition,
explain in greater detail how you considered disclosing the effects of
potential weather-
related disruptions to the operations of your customers.
Please contact Erin Donahue at 202-551-6063 or Sergio Chinos at
202-551-7844 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing