March 31, 2020

Craig A. Lampo
Senior Vice President and Chief Financial Officer
Amphenol Corporation
358 Hall Avenue
Wallingford, Connecticut 06492

       Re: Amphenol Corporation
           Form 10-K for the Fiscal Year Ended December 31, 2019
           Filed February 12. 2020
           File No. 001-10879

Dear Mr. Lampo:

       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 December 31, 2019

Notes to Consolidated Financial Statements
Note 13 - Reportable Business Segments and International Operations, page 74

1.    We note your disclosure that the Company has two reportable business
segments:
      (i) Interconnect Products and Assemblies and (ii) Cable Products and
Solutions. We also
      note your disclosure that the Company organizes its reportable business
segments based
      on similar economic characteristics and business groupings of products,
services, and
      customers. Please tell us, and clarify in future filings, whether you are
aggregating
      operating segments into your Interconnect Products and Assemblies
reportable segment as
      required by ASC 280-10-50-2. If you are aggregating operating segments,
please also
      address the following:

           Identify your operating segments;
 Craig A. Lampo
Amphenol Corporation
March 31, 2020
Page 2
              Demonstrate to us how you determined your aggregation of
operating segments
              complies with the requirements of ASC 280-10-50-11, including how
you concluded
              they exhibit similar economic characteristics; and

              Explain to us how you determined you have two reporting units for
goodwill
              impairment testing based on the requirements of ASC 350-20.
2.       We note you identify eight primary end markets in your Business
Section including:
         Automotive; Broadband Communications; Commercial Aerospace;
Industrial;
         Information Technology and Data Communications; Military; Mobile
Devices; and
         Mobile Networks. We also note you identify eight operating groups on
your website
         including: Military and Aerospace; Automotive Products; Industrial
Products; Mobile
         Consumer Products; Interconnect and Sensor Systems; Information
Communications and
         Commercial Products; RF, Optics and Broadband; and Sensor Technology
and your
         Management Team identifies Senior Vice Presidents and Group General
Managers or
         Vice Presidents and Group General Managers for each operating group.
Please address
         the following:

              Explain to us how your operating groups are reflected in your
reportable segments;

              Tell us how you assessed whether each operating group is an
operating segment as
              defined in ASC 280-10-50-1 and explain to us the nature and
extent of the discrete
              financial information available for operating groups. If you have
determined that
              your operating groups are not operating segments, fully explain
to us how you made
              that determination;

              Identify your CODM and explain to us how that determination was
made; and

              Describe the nature and extent of the financial information
reviewed by the CODM to
              assess performance and allocate resources.

        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 Andi Carpenter at 202-551-3645 or Anne McConnell at
202-551-
3709 if you have questions regarding comments.



FirstName LastNameCraig A. Lampo                              Sincerely,
Comapany NameAmphenol Corporation
                                                              Division of
Corporation Finance
March 31, 2020 Page 2                                         Office of
Manufacturing
FirstName LastName