January 8, 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 November 26, 2019 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
October 31, 2019 letter.

Form 10-K for the Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis and Results of Operations
Consolidated Net Revenues, page 44

1.    In your response to prior comment 1 you indicate that the quantified
discussion of the
      changes in revenue from each of your reportable segments provides the
material period-
      over-period changes in your consolidated net revenues. The change in the
      segment net revenues, as provided in your consolidated net revenue
discussion, can easily
      be obtained from your financial statement footnotes; however, the impact
of the various
      factors that affected such change is not evident from your disclosures.
For instance, you
      state that the increase in consolidated net revenues for fiscal 2018 was
due, in part, to an
      increase of $455 million in revenues from Activision, which you attribute
to higher
      revenues from the Destiny franchise, Call of Duty: WWII, Call of Duty:
Black Ops 4 and
 Dennis Durkin
Activision Blizzard, Inc.
January 8, 2020
Page 2
       Spyro Reignited Trilogy, offset by lower revenues from Call of Duty:
       Wars. While we acknowledge the additional quantitative disaggregation
information you
       provide (e.g. revenue by distribution channel, platform and geography),
please explain
       further to us why you believe it is not necessary to provide quantified
       regarding how your key franchises have impacted your revenues. In this
regard, you state
       on page 3 that building strong established franchises and creating new
franchises through
       compelling content is at the core of your business, and you specifically
cite such
       franchises as having an impact on your revenue. In your response, please
provide us with
       a breakdown of your key franchise titles for each period presented.
Note 2. Summary of Significant Accounting Policies
Revenue Recognition , page F-17

2.     We note your response to prior 4 as well as comments 5 and 6 in your
September 19, 2019
       response letter. We continue to evaluate your responses and may have
further comments.
        You may contact David Edgar, Staff Accountant at (202) 551-3459 or
Kathleen Collins,
Accounting Branch Chief at (202) 551-3499 if you have questions regarding
comments on the
financial statements and related matters.

FirstName LastNameDennis Durkin
                                                           Division of
Corporation Finance
Comapany NameActivision Blizzard, Inc.
                                                           Office of Technology
January 8, 2020 Page 2
cc:       Jarva Brown
FirstName LastName