Mail Stop 6010

								March 22, 2006

Via U.S. Mail and Facsimile

Mr. William J. Ruehle
Senior Vice President and Chief Financial Officer
Broadcom Corporation
16215 Alton Parkway
Irvine, California 92618-3616

Re:	Broadcom Corporation
	Form 10-K for Fiscal Year Ended December 31, 2004
      Filed March 1, 2005
	File No. 000-23993

Dear Mr. Ruehle:

      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document in future filings in response to these
comments.
If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary.  Please be
as
detailed as necessary in your explanation.  In some of our
comments,
we may ask you to provide us with information so we may better
understand your disclosure.  After reviewing this information, we
may
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 8-K filed October 20, 2005

Exhibit 99.1

1. Please refer to prior comment one. Your proposed disclosures
related to the non-GAAP measures do not include all of the
disclosures required by paragraph (e)(1)(i) of Item 10 of
Regulation
S-K and Question 8 of the FAQ Regarding the Use of Non-GAAP
Financial
Measures dated June 13, 2003 for each separate non-GAAP measure.
Your
proposed disclosures are generic and vague and discuss the
specific
adjustments rather than providing sufficient information to
understand each non-GAAP measure. Please revise to specifically
include a discussion, in sufficient detail, of the following for
each
non-GAAP measure:
?	The substantive reasons why management believes each non-GAAP
measure provides useful information to investors;
?	The specific manner in which management uses each non-GAAP
measure to conduct or evaluate its business;
?	The economic substance behind management`s decision to use
each
measure; and
?	The material limitations associated with the use of each non-
GAAP measure as compared to the use of the most directly
comparable
GAAP measure and the manner in which management compensates for
these
limitations when using the non-GAAP measure.
In addition, clarify why you believe that the adjustments for non-
GAAP measures occurring each period such as stock based
compensation,
employer payroll tax expense, gains or losses on strategic
investments, etc. do not relate to your ongoing operations.

2. We note your disclosure that management uses these measures "in
evaluating its ongoing operations, [and] managing and benchmarking
performance."  We also note the disclosures that these non-GAAP
measures are used by management in evaluating operating
performance
and comparing performance with internal forecasts and its
operating
model.  Please confirm that the adjustments reflected in your non-
GAAP measures are also reflected in, and are consistent with, the
measurement principles you use to assess segment performance
pursuant
to SFAS 131.  Otherwise, discuss the reasons for any differences
in
the two approaches.  We may have further comments.

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  When sending supplemental
information regarding this filing, please include the following
ZIP+4
code in our address: 20549-6010.  Please understand that we may
have
additional comments after reviewing your responses to our
comments.

	You may contact Lynn Dicker at (202) 551-3616 or me at (202)
551-3676 if you have questions regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Martin James, Senior Assistant Chief Accountant, at (202)
551-3671.


      Sincerely,



Brian Cascio
Accounting Branch Chief


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Mr. William J. Ruehle
Broadcom Corporation
March 22, 2006
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