May 8, 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
            For 10-Q for the Fiscal Quarter Ended March 31, 2025
            File No. 001-03761
Dear Rafael Lizardi:

       We have reviewed your filings 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.

For 10-Q for the Fiscal Quarter Ended March 31, 2025
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations - First Quarter 2025 Compared with First Quarter 2024,
page 16

1.     We note your effective tax rate declined to 8% in the first quarter of
2025. We further
       note that the reason for this decline is not addressed in any detail in
your income tax
       footnote or in your MD&A analysis of results. Please revise future
filings to explain
       in reasonable detail any significant fluctuations in your effective tax
rate, including
       whether this resulted from an unusual or infrequent event that would
cause reported
       financial information not to be necessarily indicative of future
operating results.
Form 10-K for the Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview, page 18

2.     In future filings, please include a discussion of the economic or
industry-wide factors
       that affect the quality of, and potential variability of, your earnings
and cash flow, so
       that investors can ascertain the likelihood that past performance is
indicative of future
 May 8, 2025
Page 2

       performance. For example, you discussed during your quarterly earnings
calls that
       your company's results were impacted by the industry-wide trend of
semiconductor
       customers accumulating chip stockpiles during the pandemic to mitigate
potential
       supply chain disruptions, which led to higher volumes of chip purchases
during the
       pandemic, and the subsequent drawing down of their excess chip inventory
led to
       reduced volumes of chip purchases. This factor is not discussed in your
December 31,
       2024 Form 10-K or subsequent March 31, 2025 Form 10-Q. In addition,
please
       consider addressing other broad economic or industrywide events or
uncertainties as
       they occur. Refer to Item 303 of Regulation S-K and SEC Release Nos.
33-6835 and
       33-8350.
Results of Operations, page 19

3.     We note your analysis of changes in revenue is limited to indicating
that revenue from
       your Analog segment declined due to the product mix, and revenue from
your
       Embedded Processing segment and revenue from other operations declined
due to
       lower volume from lower demand. To better achieve the objective of
providing
       sufficient insight for a reader to see the business through the eyes of
management,
       please revise future filings to provide a more informative analysis of
material changes
       in your revenue. In doing so, please disclose both the extent to which
changes in each
       of price, volume, and product mix had a material impact on your
consolidated and
       segment revenue and disclose management's insight into the reasons
underlying those
       material changes in price, volume, and product mix. Refer to Item 303 of
Regulation
       S-K and SEC Release Nos. 33-6835 and 33-8350.
4.     We note your analysis of the segment profit measure used by the CODM,
Operating
       Profit, on both a consolidated and segment basis and have the following
comments:
           Where you indicate that multiple factors contributed to a material
change in your
          results, including but not limited to your analysis of operating
profit, please revise
          future filings to quantify the impact of each material factor
identified.
           Additionally, please revise future filings to provide a more
detailed analysis of
          material changes in your operating profit and, if appropriate, a
separate detailed
          analysis of changes in revenue, cost of revenue, and operating
expenses for each
          of your Analog and Embedded Processing segments and other operations.
5.     Please revise future filings to include matters that had or are
reasonably likely to have
       a material impact on the relationship between costs and revenues. For
example, you
       mention during your year-end earnings calls that your Embedded
Processing segment
       is disproportionately impacted by fixed manufacturing costs from your
LFAB facility,
       contributing to a significantly larger decline in its 2024 operating
profit margin as
       compared to your Analog segment. In addition, constructing or expanding
fabrication
       facilities may impact your fixed costs in 2025 and could impact the
relative allocation
       of costs between your segments. Refer to Item 303 of Regulation S-K and
SEC
       Release Nos. 33-6835 and 33-8350.
Financial Condition, page 20

6.     We note your inventory increased during each of 2023 and 2024, despite
the fact that
       your sales volume declined in each of those two years. While you
currently identify
 May 8, 2025
Page 3

       the increase in the dollar amount and days of inventory in 2024, please
revise future
       filings to provide additional insight into the reasons underlying this
increase. In doing
       so, please consider disclosing the strategic decision to bring
production of your chips
       in-house, the gearing up of your LFAB facility, and that bringing
production of your
       chips in-house and building up your inventory will better position you
to meet the
       anticipated increase in demand in the next semiconductor cycle upturn.
These items
       were mentioned during your quarterly earnings calls. Refer to Item 303
of Regulation
       S-K and SEC Release Nos. 33-6835 and 33-8350.
Note 2 - Basis of presentation and significant accounting policies and
practices, page 32

7.     Please revise future filings to disclose information about recently
issued accounting
       standards you have not yet adopted, including:
           A brief description of the new standard, the date that adoption is
required and the
           date that you plan to adopt, if earlier;
           A discussion of the methods of adoption allowed by the standard and
the method
           that you expect to use; and
           A discussion of the impact that adoption of the standard is expected
to have on the
           financial statements or that the effect is not known or reasonably
estimable.
       Refer to SAB 74 (Topic 11M).
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       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