March 12, 2020

Vichheka Heang
Vice President and Corporate Controller
Maxeon Solar Technologies, Pte. Ltd.
8 Marina Boulevard #05-02
Marina Bay Financial Centre
018981, Singapore

       Re: Maxeon Solar Technologies, Pte. Ltd.
           Draft Registration Statement on Form 20-F
           Filed December 20, 2019
           CIK No. 0001796898

Dear Ms. Heang:

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

       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

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

Amendment No.1 to Registration Statement on Form 20-F

Reconciliation of Non-GAAP Financial Measures, page 90

1.    We note your response to prior comment 2 and continue to believe the cost
of above-
      market polysilicon adjustment represents an individually tailored
accounting principle
      prohibited under Regulation G. Please revise. Refer to Question 100.04 of
the Non-GAAP
      Compliance and Disclosure Interpretations.
        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 Sisi Cheng at 202-551-5004 or John Cash at 202-551-3768
if you have
questions regarding comments on the financial statements and related matters.
Please contact
 Vichheka Heang
Maxeon Solar Technologies, Pte. Ltd.
March 12, 2020
Page 2

Sherry Haywood at 202-551-3345 or Jay Ingram at 202-551-3397 with any other

FirstName LastNameVichheka Heang                        Sincerely,
Comapany NameMaxeon Solar Technologies, Pte. Ltd.
                                                        Division of Corporation
March 12, 2020 Page 2                                   Office of Manufacturing
FirstName LastName