United States securities and exchange commission logo
April 8, 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 reviewed your March 14, 2024 response to our comment
letter and have the
following comment.
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. Unless
we note otherwise, any references to prior comments are to comments in
our February 22,
2024 letter.
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
1. We have considered your
response to prior comment 2; however, we note Item 303(b)(3)
defines CAEs as
estimates made in accordance with generally accepted accounting
principles that involve
a significant level of estimation uncertainty and have had or are
reasonably likely to
have a material impact on financial condition or results of operations.
We also note CAE
disclosures should supplement, but not duplicate, the accounting
policies in the notes
to the financial statements and, for each CAE, the disclosures should
address, to the extent
material and reasonably available, the following:
Jon Faust
Sanmina Corporation
April 8, 2024
Page 2
Why the CAE is subject to uncertainty;
How much the CAE or assumption (or both) changed during the
relevant periods; and
The sensitivity of reported amounts to the methods,
assumptions, and estimates
underlying the CAE s calculation.
Based on these requirements and the information provided in your
response letter, it
appears to us you should revise future filings to disclose the impact
of favorable and
unfavorable changes in contract estimates during each period
presented. If you continue to
believe the disclosures are not material, please provide us your SAB
99 materiality
analysis that includes both quantitative and qualitative factors
considered in your
assessment of materiality and supports your conclusion that the effect
of changes in
estimates are not material to your financial statements. Please be
advised since changes in
estimates impact Operating Income and Net Income, any materiality
assessment should
not be limited to the impact on revenue and gross profit.
Please contact Jean Yu at 202-551-3305 or Anne McConnell at 202-551-3709
if you have
questions regarding comments on the financial statements and related matters.
FirstName LastNameJon Faust Sincerely,
Comapany NameSanmina Corporation
Division of
Corporation Finance
April 8, 2024 Page 2 Office of
Manufacturing
FirstName LastName