MicroVision, Inc.

6244 185th Avenue NE, Suite 100

Redmond, WA 98052

August 5, 2016

BY EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Martin James, Kate Tillan, David Burton

Ladies and Gentlemen:

MicroVision, Inc. (the “Company”) hereby submits this response to the comment letter dated July 26, 2016 of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission relating to the Company’s above-referenced Annual Report on Form 10-K. For your convenience, we have reproduced the Staff’s comments in italics below, followed by the Company’s responses.

Form 10-K for the Fiscal Year Ended December 31, 2015

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Revenue recognition, page 15

Response to Comment 1:

In response to the Staff’s comment, in future filings the Company will expand its discussion to include a description of its accounting for royalty revenue.

Results of Operations

Cost of product revenue and contract revenue, page 18

Response to Comment 2:

In response to the Staff’s comment, in future filings the Company will expand these sections to discuss the composition of these costs, including a description of the significant components of direct costs and allocated indirect costs.

Item 8. Financial Statements

Note 2. Summary of Significant Accounting Policies

Inventory, page 31

Response to Comment 3:

The Company advises the Staff that the cost of inventory is computed using the first-in, first-out (FIFO) method.

In response to the Staff’s comment, in future filings the Company will provide the disclosures required by ASC 330-10-50-1.

Concentration of Credit Risk and Major Customers and Suppliers, page 33

Response to Comment 4:

In response to the Staff’s comment, in future filings, when revenues from transactions with a single external customer amount to 10 percent or more of the Company’s total revenues, the Company will disclose that fact along with the total amount of revenues from that customer.

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Note 3. Long-term Contracts, page 36

Response to Comment 5:

The Company advises the Staff that the amount of royalty revenues recognized in fiscal 2015 related to the upfront fee was $849,000. We expect to recognize the upfront fee on a straight line basis over the term of the agreement, resulting in recognition of approximately $1.0 million ($999,000 to $1,002,000 depending upon leap years) in royalty revenue resulting from the upfront fee in each of the years from 2016 through 2022, and we expect to recognize the residual $151,000 of the upfront fee during the first fiscal quarter of 2023. On the balance sheet as of December 31, 2015, $1,002,000 of the unrecognized portion of the upfront fee was presented as the current portion of deferred revenue, and the remaining $6,149,000 was presented as the non-current portion of deferred revenue.

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The Company hereby acknowledges that (i) it is responsible for the adequacy and accuracy of the disclosure in its filings; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and (iii) it is the Staff’s view that the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We hope that the foregoing has been responsive to the Staff’s comments. If you have any questions relating to the foregoing, please contact the undersigned at (425) 882-6625, Joel Freedman of Ropes & Gray LLP at (617) 951-7309, or Tom Fraser of Ropes & Gray LLP at (617) 951-7063.

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