United States securities and exchange commission logo
February 22, 2024
Jon Faust
Chief Financial Officer
Sanmina Corporation
2700 N. First St
San Jose, CA 95134
Re: Sanmina Corporation
Form 10-K for the
Fiscal Year Ended September 30, 2023
Form 8-K filed
November 6, 2023
File No. 000-21272
Dear Jon Faust:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment(s).
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 8-K filed November 6, 2023
Exhibit 99.1
Additional Highlights, page 1
1. We note you present
Non-GAAP Pre-tax ROIC but do not present the most directly
comparable GAAP
measure, GAAP Pre-tax ROIC with equal or greater prominence. For
each non-GAAP financial
measure you present, please present the most directly
comparable GAAP measure
with equal or greater prominence as required by Item
10(e)(1)(i)(A) of
Regulation S-K and Question 102.10 of the Division of Corporation
Finance s Compliance
& Disclosure Interpretations on Non-GAAP Financial Measures.
Jon Faust
FirstName LastNameJon Faust
Sanmina Corporation
Comapany22,
February NameSanmina
2024 Corporation
February
Page 2 22, 2024 Page 2
FirstName LastName
Form 10-K for the Fiscal Year Ended September 30, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies and Estimates
Revenue Recognition, page 35
2. We note for certain contracts your application of the cost-to-cost
method for revenue
recognition requires the use of significant judgments with respect to
estimated materials,
labor, and subcontractor costs, included in the total estimated costs
at completion. You
indicate such estimates are updated on a quarterly basis and if a
change in estimate is
deemed necessary, the impact of the change is recognized in the period
of change. Please
tell us whether you have recognized any material favorable or
unfavorable changes in
estimates with respect to such contracts and tell us the gross amounts
of favorable and
unfavorable changes recognized during each period presented as part of
your response.
If material, please revise your disclosure to include the impacts of
changes in estimate
pursuant to Item 303(b)(3) of Regulation S-K.
Consolidated Financial Statements
Note 6. Financial Instruments and Concentrations of Credit Risk, page 62
3. We note certain customers represented "10% or more" of net sales
during the periods
presented. Please disclose the amount or percentage of net sales from
each significant
customer during each period presented and identity the segment or
segments reporting the
net sales as required by ASC 280-10-50-20 and ASC 280-10-50-42.
Note 15. Business Segments and Customer Information, page 73
4. Please provide the disclosures required by ASC 280-10-50-40. In this
regard, we note
your disclosures under Business appear to describe various products
and services included
in both your IMS and CPS reportable segments. In addition, please also
provide all the
disclosures required by ASC 280-10-50-20 and ASC 280-10-50-41. In this
regard, we
note your disclosures related to net sales from material individual
foreign countries in
Note 4 are only provided for the current fiscal year. We also note
your current disclosures
provide property, plant and equipment by geographic segment but you do
not separately
disclose your long-lived assets located in the US and by individual
foreign countries,
where material.
Jon Faust
FirstName LastNameJon Faust
Sanmina Corporation
Comapany22,
February NameSanmina
2024 Corporation
February
Page 3 22, 2024 Page 3
FirstName LastName
In closing, 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.
Please contact Jean Yu at 202-551-3305 or Anne McConnell at 202-551-3709
with any
questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing