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                               September 8, 2020

       Paul R. Lundstrom
       Chief Financial Officer
       FLEX LTD.
       2 Changi South Lane
       Singapore 486123

                                                        Re: FLEX LTD.
                                                            Form 10-K for the
Year Ended March 31, 2020
                                                            Filed May 28, 2020
                                                            Form 10-Q for the
Period Ended June 26, 2020
                                                            Filed August 5,
2020
                                                            File No. 000-23354

       Dear Mr. Lundstrom:

              We have reviewed your filing 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-Q for the Quarterly Period Ended June 26, 2020

       Results of Operations
       Gross profit, page 31

   1.                                                   Please revise this
discussion in future filings to separately quantify and discuss factors
                                                        responsible for changes
in the levels of your cost of sales, including the impact of material
                                                        variances in components
that offset each other. Consider providing this information by
                                                        segment also. Refer to
our interpretive guidance provided in SEC Release FR-72.
   2.                                                   In a related matter,
where multiple factors result in period over period variances in future
                                                        filings, please revise
your MD&A discussions of these income and expense line items to
                                                        identify and quantify
the relative contribution of each of the factors and to explain the
                                                        reason for the changes.
Refer to SEC Release FR-72.
 Paul R. Lundstrom
FLEX LTD.
September 8, 2020
Page 2
Segment Income, page 32

3.    We note that in the tables on pages 32 ad 33 you present total segment
income and total
      segment margin amounts, which appear to be non-GAAP measures as noted in
Question
      104.04 of the Compliance & Disclosure Interpretations on Non-GAAP
Financial
      Measures. Please revise your future filings to identify the measures as
non-GAAP and to
      provide the disclosures required by Item 10(e) of Regulation S-K.
        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.

       You may contact Effie Simpson at (202) 551-3346 or Martin James at (202)
551-3671 if
you have questions regarding comments on the financial statements and related
matters. Please
contact the undersigned at (202) 551-3379 with any other questions.



                                                          Sincerely,
FirstName LastNamePaul R. Lundstrom
                                                          Division of
Corporation Finance
Comapany NameFLEX LTD.
                                                          Office of
Manufacturing
September 8, 2020 Page 2
cc:       Heather Childress
FirstName LastName