Maxeon Solar Technologies, Ltd.

8 Marina Boulevard #05-02

Marina Bay Financial Centre

018981, Singapore

 

Via Edgar

 

June 17, 2024

 

United States Securities and Exchange Commission

 

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Bradley Ecker

 

Re:	Maxeon Solar Technologies, Ltd. and Co-Applicants
	Application for Qualification of Indenture Under the Trust Indenture Act of 1939 on Form T-3 File No.: 022-29114

 

Ladies and Gentlemen:

 

We refer to the Application for Qualification of Indenture Under the Trust Indenture Act of 1939 on Form T-3 (File No. 022-29114) (the “Form T-3”) of Maxeon Solar Technologies, Ltd. (the “Company”) and the subsidiary guarantors named therein (together with the Company, the “Applicants”), initially filed on May 30, 2024 with the Securities and Exchange Commission (the “Commission”), in connection with the qualification under the Trust Indenture Act of 1939, as amended (the “Act”), of the indenture governing the Adjustable-Rate Convertible Second Lien Senior Secured Notes due 2028 to be issued by the Company and guaranteed by the Company’s subsidiary guarantors.

 

In accordance with Section 307(c) of the Act, the Applicants hereby respectfully request the acceleration of the effectiveness of the above referenced Form T-3 so that it may become effective at or prior to 9:00 a.m. (Eastern time) on June 20, 2024 or as soon as reasonably practicable thereafter.

 

If you have any questions regarding the foregoing, please contact Kaya Proudian of White & Case Pte. Ltd. at +65 6347 1308.

 

	Very truly yours,
	Maxeon Solar Technologies, Ltd.
	By:	/s/ Kai Strohbecke
	Name:	Kai Strohbecke
	Title:	Chief Financial Officer

 

[Signature Page Follows]

 

 

	SUNPOWER CORPORATION LIMITED
	By:	/s/ Peter Aschenbrenner
	Name:	Peter Aschenbrenner
	Title:	Director
	SUNPOWER ENERGY CORPORATION LIMITED
	By:	/s/ Kai Strohbecke
	Name:	Kai Strohbecke
	Title:	Director
	SUNPOWER MANUFACTURING CORPORATION LIMITED
	By:	/s/ Kai Strohbecke
	Name:	Kai Strohbecke
	Title:	Director
	MAXEON ROOSTER HOLDCO, LTD.
	By:	/s/ Kai Strohbecke
	Name:	Kai Strohbecke
	Title:	Director
	MAXEON SOLAR PTE. LTD.
	By:	/s/ Kai Strohbecke
	Name:	Kai Strohbecke
	Title:	Director
	SUNPOWER BERMUDA HOLDINGS
	By:	/s/ Kai Strohbecke
	Name:	Kai Strohbecke
	Title:	Director

 

 

	SUNPOWER TECHNOLOGY LTD.
	By:	/s/ Kai Strohbecke
	Name:	Kai Strohbecke
	Title:	Authorized Signatory
	SUNPOWER PHILIPPINES MANUFACTURING LTD.
	By:	/s/ Kai Strohbecke
	Name:	Kai Strohbecke
	Title:	Authorized Signatory
	ROOSTER BERMUDA DRE, LLC
	By:	/s/ Kai Strohbecke
	Name:	Kai Strohbecke
	Title:	Authorized Signatory
	SUNPOWER SYSTEMS SÀRL
	By:	/s/ Kai Strohbecke
	Name:	Kai Strohbecke
	Title:	Authorized Signatory