United States securities and exchange commission logo

                              September 8, 2021

       Jeff Worth
       Vice President and General Counsel
       400 Stonebreak Road Extension
       Malta, NY 12020

                                                        Re: GLOBALFOUNDRIES
                                                            Draft Registration
Statement on Form F-1
                                                            Filed August 9,
                                                            CIK No. 0001709048

       Dear Mr. Worth:

              We have reviewed your draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       DRS filed 8/9/2021

       Prospectus Cover Page, page i

   1.                                                   We note your disclosure
elsewhere in the prospectus that you will be
                                                        a controlled company
following the completion of the offering. Please include similar
                                                        disclosure on the cover
page of your prospectus.
       Summary Consolidated Financial Data
       Non-IFRS Reconciliations, page 18

   2.                                                   We note that the
reconciling items titled (Gains) losses on transactions, legal settlements
                                                        and transaction
expenses may include offsetting adjustments and even on a net basis,
                                                        represents 37% of
Adjusted EBITDA. Please disclose the composition to such line item
 Jeff Worth
FirstName  LastNameJeffInc.
Comapany 8,
              2021             Inc.
Page 2     8, 2021 Page 2
FirstName LastName
         to enable an investor to understand the nature of each component
impacting this
         adjustment and to ensure that it does not include any costs that are
normal, recurring cash
         operating expenses necessary to operate your business. Refer to
Question 100.01 of the
         Division's Compliance and Disclosure Interpretations for Non-GAAP
Financial Measures.
The Cayman Islands Economic Substance Law may affect our operations., page 48

3.       Please revise to clarify what this law entails and how it may affect
your business and
Use of Proceeds, page 56

4.       We note your disclosure that you intend to use a portion of the
proceeds to
         repay indebtedness. Please disclose in your Use of Proceeds section
the additional
         information required by Instruction 4 to Item 504 of Regulation S-K.
Capitalization, page 58

5.       Given the anticipated change in capitalization due to the conversion
of loans provided
         under the loan facilities with Mubadala Investment Company PJSC to
additional paid-in
         capital immediately prior to the consummation of this offering, please
tell us how you
         considered providing a pro forma presentation of the affected line
items on the face of
         your statement of financial position as well as pro forma loss per
share on the face of your
         statements of operations and comprehensive loss, or providing such
disclosure elsewhere
         in the prospectus. Refer to Rule 11-01(a)(8) of Regulation S-X.
6.       Please expand the footnote pertaining to the anticipated conversion by
         Investment Company PJSC of the Loan from shareholder under the loan
facilities with
         Mubadala from 2012 to 2016 to additional paid-in capital immediately
prior to the
         consummation of this offering to provide discussion of the anticipated
conversion. Such
         information should include, but not be limited to, the number of
shares such loans are
         converted into, the conversion price, and how the conversion ratio was
         determined. Additionally, expand disclosure in your Dilution section
to give effect to
         such conversion.
Strategic Repositioning, page 61

7.       Please expand the fourth bullet to provide more specific details
regarding the disclosed
         plan, particularly considering that it appears you have generated a
negative gross margin
         percentage for each period presented.
Business, page 82

8.       Please include a corporate organizational chart in your Business
section depicting your
         structure following this offering. Clarify which entities are
organized in which countries,
         including Mubadala, MTIC, and MTI International Investment Company
LLC. Include in
         the chart the ownership and voting control of Mubadala and that of
public shareholders
 Jeff Worth
September 8, 2021
Page 3
         following completion of the offering.
Corporate Opportunity, page 135

9.       Please amend your filing to provide relevant risk factor disclosure
related to the removal
         of the corporate opportunity doctrine provisions from your charter,
including the conflicts
         of interest that may result from the provision.
Consolidated Statements of Financial Position, page F-7

10.      We note that you present the Loan from shareholder within equity at
December 31, 2020.
         Further we note that such note is non-interest bearing and has no set
maturity date, with
         principal repayment in whole or in part at your discretion. Please
provide to us a fulsome
         analysis including specific terms of the agreement, used to determine
that equity
         classification is appropriate as discussed in Note 32. Cite the
authoritative guidance that
         you considered in arriving at your accounting treatment.
       You may contact Effie Simpson at (202) 551-3346 or Mark Rakip at (202)
551-3573 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Sherry Haywood at (202) 551-3345 or Geoffrey Kruczek at (202) 551-3641
with any
other questions.

FirstName LastNameJeff Worth                                   Sincerely,
                                                               Division of
Corporation Finance
September 8, 2021 Page 3                                       Office of
FirstName LastName