February 14, 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 amended 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 response.

      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
comments.



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

Notes to Unaudited Pro Forma Combined Financial Information, page 24

1.     You state in your response to prior comment 2 that the promissory note
of $100.0 million
       represents a net parent distribution and is not intended to be
reflective of fair value of the
       intellectual property to be transferred. Please tell us how you
considered including pro
       forma disclosure, including pro forma per share data in the historical
financial statements
       with appropriate footnote disclosure, to give effect to the planned net
parent distribution.
       Refer to SAB Topic 1.B.3.
 Vichheka Heang
Maxeon Solar Technologies, Pte. Ltd.
February 14, 2020
Page 2
Reconciliation of Non-GAAP Financial Measures, page 90

2.       You indicate in your response to prior comment 4 that the cost of
above-market
         polysilicon adjustment relates to legacy long-term, fixed price supply
agreements
         executed by SunPower to purchase polysilicon. Please tell us in more
detail about these
         legacy long-term agreements including the material provisions such as
term, cancellation
         provisions and if management expects to exit these contracts in the
near future. In this
         regard, it is not clear why management believes these costs are
non-recurring and should
         not be reflected as current period operating costs. Please explain and
tell us how you
         considered the guidance found in Question 100.01 of the Non-GAAP
Compliance and
         Disclosure Interpretations.
Financial Statements
General, page F-1

3.       Please note the financial statement updating requirements per Item
8.A. of Form 20-F.
       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
Sherry Haywood at 202-551-3345 or Jay Ingram at 202-551-3397 with any other
questions.



FirstName LastNameVichheka Heang                             Sincerely,
Comapany NameMaxeon Solar Technologies, Pte. Ltd.
                                                             Division of
Corporation Finance
February 14, 2020 Page 2                                     Office of
Manufacturing
FirstName LastName