United States securities and exchange commission logo
September 14, 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
August 24, 2022
File No. 001-38449
Dear Ms. Spears:
We have reviewed your August 24, 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
August 4, 2022 letter.
Response Dated August 24, 2022
Risk Factors, page 13
1. We note your response
to prior comment one regarding transition risks related to climate
change. Please clearly
describe the specific transition risks you have considered,
including those
identified in our comment, and provide additional detail regarding their
material effects, along
with support for your determination of materiality for purposes of
disclosure.
Kirsten Spears
FirstName LastNameKirsten Spears
Broadcom Inc.
Comapany 14,
September NameBroadcom
2022 Inc.
September
Page 2 14, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
35
2. As your response to comment three does not provide all of the
requested information, it is
reissued in part. Please include the quantification requested with
regards to the cost of
insurance on an aggregate basis for each of the periods covered by
your Form 10-K.
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