InterDigital Inc (IDCC)

[Gamco]

Any observations?
..............
United States securities and exchange commission logo July 20, 2022 Richard J. Brezski Chief Financial Officer InterDigital, Inc. 200 Bellevue Parkway, Suite 300 Wilmington, DE 19809 Re: InterDigital, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 17, 2022 File No. 001-33579 Dear Richard J. Brezski: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2021 Notes to Consolidated Financial Statements 2. Summary of Significant Accounting Policies and New Accounting Guidance Compensation Programs, page 65 1. Please tell us how you considered the guidance in SAB Topic No. 14.D.2 Question 6 in your determination to use the simplified method rather than historical exercise data to estimate the expected term of stock options. In addition, please tell us what consideration you gave to enhancing your footnote to disclose why the simplified method was used. Richard J. Brezski InterDigital, Inc. July 20, 2022 Page 2 In closing, 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. You may contact Frank Knapp, Staff Accountant at [phone] or Jennifer Monick, Assistant Chief Accountant at [phone] with any questions. FirstName LastNameRichard J. Brezski Sincerely, Comapany NameInterDigital, Inc. Division of Corporation Finance July 20, 2022 Page 2 Office of Real Estate & Construction FirstName LastName