July 16, 2025
Rafael Lizardi
Chief Financial Officer
Texas Instruments Inc
12500 TI Boulevard
Dallas, TX 75243
Re: Texas Instruments Inc
Form 10-K for the Fiscal Year Ended December 31, 2024
Response Dated June 26, 2025
File No. 001-03761
Dear Rafael Lizardi:
We have reviewed your June 26, 2025 response to our comment letter and
have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our May 8,
2025 letter.
Form 10-K for the Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 18
1. We note your response to prior comment 1. As the term "discrete tax
benefits" could
refer to a variety of situations giving rise to adjustments to your
income taxes during
the quarter, please revise your upcoming Form 10-Q to explain in
reasonable detail
the nature of and amounts related to each type of material discrete tax
benefit that
contributed to the fluctuation in your effective tax rate. Please
include your proposed
future disclosure with your response.
July 16, 2025
Page 2
2. We note your response to prior comment 2. In your upcoming Form 10-Q,
please
describe the economic or industry-wide factors that affect the quality
of, and potential
variability of, your earnings and cash flow, providing similar
transparency and
granularity to the information conveyed on your earnings calls. Please
include your
proposed future disclosure with your response.
3. We note your response to prior comments 3 through 6 and reissue the
comments. In
your upcoming Form 10-Q, please provide a more informative analysis of
the
underlying factors contributing to material changes to your results of
operations and
your financial condition. In doing so, please provide similar
transparency and
granularity to the information conveyed on your earnings calls. Please
include your
proposed future disclosure with your response.
4. We note your response to prior comment 7. Please provide us with your
proposed
future disclosure of recently issued accounting standards you have not
yet adopted.
Please contact SiSi Cheng at 202-551-5004 or Jennifer Thompson at
202-551-3737 if
you have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing