February 10, 2020

Robert McNutt
Senior Vice President and Chief Financial Officer
Lamb Weston Holdings, Inc.
599 S. Rivershore Lane
Eagle, Idaho 83616

       Re: Lamb Weston Holdings, Inc.
           Form 10-K for Fiscal Year Ended May 26, 2019
           Filed July 25, 2019
           File No. 001-37830

Dear Mr. McNutt:

       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 May 26, 2019

Notes to the Financial Statements
Note 2. Revenue From Contracts With Customers, page 64

1.    We note your disclosure that generally, you recognize revenue on a point
in time basis
      when the customer takes title to the goods and assumes the risks,
rewards, or control of
      the goods. However, you recognize revenue over time for customized
products as they are
      produced and you have a purchase order providing a legally enforceable
right to payment
      for the goods. For performance obligations which you satisfy over time,
please tell us,
      and revise to disclose the method used to recognize revenue (for example,
a description of
      the output methods or input methods used and how those methods are
applied), and an
      explanation of why the methods used provide a faithful depiction of the
transfer of goods
      or services. See guidance in ASC 606-10-50-18.
 Robert McNutt
Lamb Weston Holdings, Inc.
February 10, 2020
Page 2
2.       Please tell us, and revise to disclose the nature of your significant
payment terms,
         including whether any of your contracts have significant financing
components. Also,
         please disclose any obligations for returns or refunds. See guidance
in ASC 606-10-50-
         12.
        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 Claire Erlanger, Staff Accountant, at 202-551-3301 or
Melissa
Raminpour, Accounting Branch Chief, at 202-551-3379 if you have questions.



FirstName LastNameRobert McNutt                              Sincerely,
Comapany NameLamb Weston Holdings, Inc.
                                                             Division of
Corporation Finance
February 10, 2020 Page 2                                     Office of
Manufacturing
FirstName LastName