January 24, 2020

Paul Parrish
Senior VP & Chief Financial Officer
SecureWorks Corp
One Concourse Parkway NE
Suite 500
Atlanta, GA 30328

       Re: SecureWorks Corp
           Form 10-K for the Fiscal Year Ended January 31, 2019
           File No. 001-37748

Dear Mr. Parrish:

       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-K for the Fiscal Year Ended January 31, 2019

Business
Overview, page 4

1.    Please disclose the dollar amount of backlog believed to be firm and
separately
      provide the portion thereof not expected to be filled within the current
year. In this
      regard, we note that your remaining performance obligation disclosure
excludes
      performance obligations with a duration of one year or less and that a
significant portion
      of your arrangements are not billed in advance. Refer to Item
101(c)(1)(viii) of
      Regulation S-K.
 Paul Parrish
FirstName LastNamePaul Parrish
SecureWorks Corp
Comapany NameSecureWorks Corp
January 24, 2020
January 24, 2020 Page 2
Page 2
FirstName LastName
Risk Factors
Our charter designates the Court of Chancery of the State of Delaware as the
sole and exclusive
forum for certain types of actions . . ., page 38

2.       You state here that your charter designates the Court of Chancery of
the State of Delaware
         as the exclusive forum for types of actions and proceedings that may
be initiated by your
         shareholders, including any "derivative action" or proceeding brought
on your behalf.
         Please disclose whether this provision applies to actions arising
under the Securities Act
         or Exchange Act. In that regard, Section 27 of the Exchange Act
creates exclusive federal
         jurisdiction over all suits brought to enforce any duty or liability
created by the Exchange
         Act or the rules and regulations thereunder, and Section 22 of the
Securities Act creates
         concurrent jurisdiction for federal and state courts over all suits
brought to enforce any
         duty or liability created by the Securities Act or the rules and
regulations thereunder. If the
         provision applies to Securities Act claims, please revise your filing
to state that there is
         uncertainty as to whether a court would enforce such provision and to
state that
         stockholders will not be deemed to have waived the company's
compliance with the
         federal securities laws and the rules and regulations thereunder. If
this provision does not
         apply to actions arising under the Securities Act or Exchange Act,
please ensure that the
         exclusive forum provision in the governing documents states this
clearly.
Consolidated Financial Statements
Note 2. Significant Accounting Policies
Revenue Recognition, page 73

3.       You state that the hardware appliances and related maintenance
agreements included in
         the subscription-based solutions arrangements are incapable of being
distinct within the
         context of the contract as they are required to access the Counter
Threat Platform. Please
         explain further the nature and delivery of your security solutions and
how you determined
         that maintenance and subscription services are not separately
identifiable from the
         hardware appliance. In this regard, your disclosure on page 9
indicates that the Counter
         Threat Appliance is a physical or virtual appliance deployed in a
customer's data center,
         branch office or cloud environment, or your own data center. Describe
the standalone
         functionality of the appliance without the subscription or maintenance
services. Also, tell
         us whether the customer retains the hardware appliance after the
initial contract term
         regardless of whether or not they renew the subscription and whether a
customer could
         use your appliance to support a third party security solution. Refer
to ASC 606-10-25-19
         and 25-21.
 Paul Parrish
FirstName LastNamePaul Parrish
SecureWorks Corp
Comapany NameSecureWorks Corp
January 24, 2020
Page 3
January 24, 2020 Page 3
FirstName LastName
        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 Joyce Sweeney, Senior Staff Accountant at (202) 551-3449
or Kathleen
Collins, Accounting Branch Chief at (202) 551-3499 if you have questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology
cc:      Teri Miller