TEXT-EXTRACT 2 filename2.txt March 12, 2019 Neil A. Manna Corporate Controller Principal Accounting Officer DXC Technology Company 1775 Tysons Boulevard Tysons, Virginia 22102 Re: DXC Technology Co Form 10-K for Fiscal Year Ended March 31, 2018 Form 10-Q for the Quarterly Period Ended December 31, 2018 File No. 001-38033 Dear Mr. Manna: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-Q for the quarterly period ended December 31, 2018 Management's Discussion and Analysis of Financial Condition and Results of Operations Reconciliation of Non-GAAP Financial Measures, page 69 1. We note that your non-GAAP Income from Continuing Operations, non-GAAP Net Income, and non-GAAP EPS measures are adjusted for Amortization of Acquired Intangible Assets. It appears that this adjustment represents an individually tailored accounting principle substituted for those in GAAP. In this regard, removing the amortization while retaining in the measure the related revenues presents a measure with apparent operating result inconsistencies. Please remove these adjustments from the calculations of these non-GAAP measures in future filings as well as in your earnings releases on Form 8-K. We refer you to Question 100.04 of the updated Compliance and Disclosure Interpretations issued on April 4, 2018. In closing, we remind you that the company and its management are responsible for the Neil A. Manna DXC Technology Company March 12, 2019 Page 2 accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or Craig Wilson, Senior Assistant Chief Accountant, at (202) 551-3226 with any questions. Sincerely, FirstName LastNameNeil A. Manna Division of Corporation Finance Comapany NameDXC Technology Company Office of Information Technologies March 12, 2019 Page 2 and Services FirstName LastName