United States securities and exchange commission logo October 25, 2022 Frank P. Sedlarcik Vice President, Assistant General Counsel and Secretary International Business Machines Corporation One New Orchard Road Armonk, New York 10504 Re: International Business Machines Corporation Definitive Proxy Statement on Schedule 14A Filed March 7, 2022 File No. 001-02360 Dear Frank P. Sedlarcik: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Disclosure Review Program