Mail Stop 0306

January 24, 2005



Via Facsimile and U.S. Mail

Mr. Kiran Patel
Executive Vice President and Chief Financial Officer
Solectron Corporation
847 Gibraltar Drive
Milpitas, California 95035

	Re:	Solectron Corporation
		Form 10-K for the year ended August 27, 2004
      Filed November 5, 2004
		Form 10-Q for the quarterly period ended November 26,
2004
Response Letter dated December 22, 2004
      File No. 001-11098


Dear Mr. Patel:

      We have reviewed the above documents and have the following
additional comments.  We have limited our review to the issues
raised
in our comments.  Where indicated, we think you should revise
future
filings in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as possible in
your
explanations.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.




Form 10-Q for the Quarterly Period Ended November 26, 2004

Item 4. Controls and Procedures - Page 38
1. We note your disclosure that your "principal executive officer
and
principal financial officer have concluded that Solectron`s
disclosure controls and procedures...are effective to ensure that
information required to be disclosed by Solectron in reports that
it
files or submits under the Exchange Act is recorded, processed,
summarized and reported within the time periods specified in
Securities and Exchange Commission rules and forms."  Revise to
clarify in future filings, if true, that your officers concluded
that
your disclosure controls and procedures are also effective to
ensure
that information required to be disclosed in the reports that you
file or submit under the Exchange Act is accumulated and
communicated
to your management, including your principal executive officer and
principal financial officer, to allow timely decisions regarding
required disclosure.  See Exchange Act Rule 13a-15(e).


*    *    *    *


      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  When sending supplemental information
regarding this filing, please include the following ZIP+4 code in
our
address: 20549-0306.  Please understand that we may have
additional
comments after reviewing your responses to our comments

      You may contact Lynn Dicker, Staff Accountant, at (202) 824-
5264 or me at (202) 942-2813 if you have questions regarding
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Martin James, the Senior Assistant Chief
Accountnant, at (202) 942-1984.


							Sincerely,



							Daniel L. Gordon
							Accounting Branch Chief


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Mr. Kiran Patel
Solectron Corporation
January 24, 2005
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