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                              September 2, 2022

       Robert Andersen
       Chief Financial Officer
       Xperi Inc.
       2190 Gold Street
       San Jose, CA 95002

                                                        Re: Xperi, Inc.
                                                            Registration
Statement on Form 10-12B
                                                            Filed August 26,
2022
                                                            File No. 001-41486

       Dear Mr. Andersen:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information 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 response.

            After reviewing your response and any amendment you may file in
response to these
       comments, we may have additional comments.

       Form 10-12B Filed on August 26, 2022

       Exhibit 99.1
       Management Discussion of Results of Operations of Xperi Product for the
Three and Six Months
       ended June 30, 2022, page 81

   1.                                                   We note your discussion
of the changes in revenue in the three and six month period
                                                        ended June 30, 2022.
Where a change is attributed to two or more factors, including any
                                                        offsetting factors, the
contribution of each identified factor should be described in
                                                        quantified terms, if
material. Please revise to quantify the impact of each material factor
                                                        affecting revenue.
Refer to Item 303(b) of Regulation S-K.
 Robert Andersen
FirstName
Xperi Inc. LastNameRobert Andersen
Comapany 2,
September  NameXperi
              2022    Inc.
September
Page 2     2, 2022 Page 2
FirstName LastName
Description of Our Capital Stock, page 161

2.       Please provide disclosure of the exclusive forum provisions contained
in your articles of
         incorporation. Also provide risk factor disclosure describing the
risks or other impacts to
         shareholders. With respect to the exclusive federal forum for
Securities Act claims, state
         that there is uncertainty as to whether a court would enforce such
provision and that
         investors cannot waive compliance with the federal securities laws and
rules and
         regulations thereunder. In that regard, we note that Section 22 of the
Securities Act creates
         concurrent jurisdiction for federal and state courts over all suits
brought to enforce any
         duty or liability created by the Securities Act or the rules and
regulations thereunder.
        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 Christine Dietz, Senior Staff Accountant, at (202)
551-3408 or Kathleen
Collins, Accounting Branch Chief, at 202-551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Kathleen Krebs,
Special Counsel,
at at 202-551-3350 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any
other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology
cc:      Mike Ringler, Esq.