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                             April 14, 2022

       Roop Lakkaraju
       Chief Financial Officer
       BENCHMARK ELECTRONICS INC
       56 South Rockford Drive
       Tempe, Arizona 85281

                                                        Re: BENCHMARK
ELECTRONICS INC
                                                            Form 10-K for the
Year Ended December 31, 2021
                                                            Filed February 25,
2022
                                                            File No. 001-10560

       Dear Mr. Lakkaraju:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.



       Form 10-K for the Year Ended December 31, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations
       2021 Compared With 2020, page 33

   1.                                                   We note that you
discuss your results of operations on a consolidated basis. Please revise
                                                        your MD&A in future
filings to also discuss the results of operations for each of your
                                                        reportable segments. If
you do not believe the segment information would provide
                                                        information necessary
for an understanding of your business, please advise. See guidance
                                                        in Item 303(b) of
Regulation S-K.
 Roop Lakkaraju
FirstName   LastNameRoop Lakkaraju
BENCHMARK        ELECTRONICS   INC
Comapany
April       NameBENCHMARK ELECTRONICS INC
       14, 2022
April 214, 2022 Page 2
Page
FirstName LastName
Consolidated Statements of Income , page 41

2.       We note from your disclosure in Note 14 that your revenue is generated
primarily from
         the sale of manufactured products built to customer specifications but
that you also
         generate revenue from design, development and engineering services. We
also note from
         your disclosure in the business section that your customer engagement
focuses on three
         principal areas: Design and Engineering Services, Technology
Solutions, and
         Manufacturing Services. Please provide for us the amount of revenue
recognized from the
         sale of products and the amount recognized related to the sale of
services for each period
         presented and tell us why you have not provide a breakout of revenue
and cost of revenue
         by products and services on the face of the statements of income as
required by Item 5-
         03(b)(1)-(2) of Regulation S-X. In addition, tell us if you track
revenue for the three
         categories referenced above or for any of the related sub-categories
detailed on pages 4-7
         of the filing.
Notes to the Financial Statements
Note 13 - Segment and Geographic Information, page 61

3.       Please tell us and revise future filings to disclose the nature of the
items included in the
         "Corporate and intersegment eliminations" line item used to reconcile
your segment profit
         and loss measure to the consolidated statements of income. See ASC
280-10-50-30 and -
         31.
Note 17 - Restructuring Charges, page 64

4.       We note that you have undertaken multiple restructuring initiatives
during the periods
         presented. For each restructuring program, please revise your
disclosures to include the
         facts and circumstances leading to the expected activity and the
expected completion
         date. In addition, for each major type of cost associated with the
activity, disclose, in total
         and by segment, the total amount expected to be incurred, the amount
incurred in the
         period, and the cumulative amount incurred to date. See guidance in
ASC 420-10-50-1.
5.       We note that you incurred $4.4 million of asset impairment charges in
the Americas
         during fiscal 2021, as well as $5.7 million and $1 million of asset
impairments in the
         Americas and Asia, respectively, during fiscal 2020. Please revise
your footnotes in
         future filings to include the disclosures required by ASC 360-10-50-2,
including a
         description of the impaired assets, the facts and circumstances
leading to the impairment,
         the caption in the statement of income that includes the loss, and the
methods for
         determining fair value.

       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.
 Roop Lakkaraju
BENCHMARK ELECTRONICS INC
April 14, 2022
Page 3

      You may contact Claire Erlanger at (202) 551-3301 or Andrew Blume at
(202) 551-
3254 with any questions.



FirstName LastNameRoop Lakkaraju                       Sincerely,
Comapany NameBENCHMARK ELECTRONICS INC
                                                       Division of Corporation
Finance
April 14, 2022 Page 3                                  Office of Manufacturing
FirstName LastName