February 3, 2020

Dennis Durkin
Chief Financial Officer
Activision Blizzard, Inc.
3100 Ocean Park Boulevard
Santa Monica, CA 90405

       Re: Activision Blizzard, Inc.
           Form 10-K for the Year Ended December 31, 2018
           Filed on February 28, 2019
           File No. 001-15839

Dear Mr. Durkin:

       We have reviewed your January 23, 2020 response to our comment letter
and have the
following comments. In some of our comments, we may ask you to provide us with
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

       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
January 9, 2020 letter.

Form 10-K for the Year Ended December 31, 2019

Note 2. Summary of Significant Accounting Policies
Revenue Recognition
Significant Judgment around Revenue Arrangements with Multiple Deliverables,
page F-18

1.    We note your response to prior comment 2. Please revise your disclosures
both here and
      in your critical accounting policies to address the following:

           Describe further the separate performance obligations for your games
with both
           online and offline functionality. For instance, in your September
19, 2019 response
           to comment 5, you state that the performance obligations for most of
your titles in the
           Call of Duty franchise include: (1) a license to the game software
that is accessible
           without an internet connection (predominantly the single-player
campaign); and
 Dennis Durkin
Activision Blizzard, Inc.
February 3, 2020
Page 2
           (2) ongoing activities associated with the online components of the
game ("online
           functionality"), most notably associated with online content
updates, hosting of the
           online content and game play, and match making. Also, ensure such
           describe the significant functionalities that are available with
your online services but
           not in the single-player campaign mode.
           Expand your discussion of the significant judgments used to
determine the standalone
           selling price for each performance obligation and ensure you address
the fact that
           your offline campaign mode is not designed for significant
replay-ability after the
           initial completion of the campaign as indicated in your November 26,
2019 response
           to comment 4.
           To the extent any factors identified in your current disclosures,
including those on
           page F-19, are not typically used in determining your standalone
selling price, please
           revise your disclosures accordingly. In this regard based on your
various responses,
           it is unclear if costs are used in such determination.

       Please provide a draft of your proposed revised disclosures in your
response. Refer to
       ASC 606-10-50-20.
      You may contact David Edgar, Staff Accountant, at (202) 551-3459 or
Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 with any questions.

FirstName LastNameDennis Durkin
                                                             Division of
Corporation Finance
Comapany NameActivision Blizzard, Inc.
                                                             Office of
February 3, 2020 Page 2
cc:       Jarva Brown
FirstName LastName