April 8, 2019

Gregory S. Clark
President, Chief Executive Officer and Director
Symantec Corporation
350 Ellis Street
Mountain View, CA 94043

       Re: Symantec Corporation
           Form 10-K for the fiscal year ended March 30, 2018
           Filed October 26, 2018
           Form 10-Q for the fiscal period ended December 28, 2018
           Filed February 4, 2019
           File No. 000-17781

Dear Mr. Clark:

       We have reviewed your March 14, 2019 responses to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in our
February 21, 2019 letter.

Form 10-K for the Year Ended March 30, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
36

1.    We note from your response to prior comment 1 that management
periodically monitors
      customer retention and renewal rates for significant changes in each of
your segments.
      Please clarify for us what you mean by "periodically monitors." Also, you
state the
      comparability of your renewal and retention rates for your Enterprise
Security segment are
      limited due to a divestiture in fiscal 2016 and an acquisition in early
fiscal 2017. Please
      explain further why transactions from two years ago continue to impact
the usefulness of
      these metrics. Also, describe further the changes made to the way you
sell your Enterprise
 Gregory S. Clark
FirstNameCorporation
Symantec LastNameGregory S. Clark
Comapany NameSymantec Corporation
April 8, 2019
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         Security arrangements and how such changes impacted the usefulness of
such measures.
         In addition, please provide us with the renewal and retention rates
for each of the
         Enterprise Security and Consumer Digital Security segments for each
quarter during the
         last three fiscal years. To the extent there have been significant
fluctuations in such
         measures, particularly for the Consumer Digital Security segment,
please explain further
         why a quantified discussion would not be useful to investors. Refer to
Section III.B.1 of
         SEC Release 33-8350.
Item 9A. Disclosure Controls and Procedures, page 52

2.       We note your response to prior comment 2. In order for us to better
understand the
         control deficiency identified and how you considered the potential
magnitude of the
         control deficiency, please address the following as it relates to the
transaction that was
         initially recorded as revenue rather than the majority of the
transaction being recorded as
         deferred revenue:

             Explain further how the revenue misstatement was discovered during
the Audit
             Committee investigation.
             Describe the transaction that resulted in this misstatement,
clarify why the accounting
             changed and cite the specific accounting guidance applied.
             Describe the standard sales process and the individuals involved
in the process, from
             negotiating to reviewing, closing, and recording a transaction,
and how segregation of
             duties is considered. If the standard process differed for this
particular transaction,
             please explain why. Please also explain if there were other
circumstances in which the
             standard process was not followed and whether the Audit Committee
reviewed and
             considered those transactions as a part of its investigation.
             Explain in more detail how the control identified in your response
works, including the
             level of precision related to this control. For example, explain
the nature of the
             revenue training and representations, and tell us why you believe
if the sales personnel
             had been involved this control would have detected the
misstatement on a timely
             basis.
             Explain in more detail the nature of the control deficiency. For
example, clarify
             whether it is a design or operating effectiveness control
deficiency. Also, explain in
             detail how the change in controls as described in your response
would have prevented
             or detected a misstatement on a timely basis.
             With regards to the maximum amount or total number of transactions
exposed to the
             deficiency, please explain in more detail how you determined the
criteria for this
             additional population. Explain the characteristics that were
unique to these additional
             transactions and the transaction resulting in the misstatement,
and describe any
             differences related to the nature of these transactions. Tell us
what percentage of your
             new 2018 sales contracts these additional contracts represented.
Additionally, tell us
             why you did not consider any new sales contracts prior to fiscal
2018 in your analysis.
             Lastly, to the extent such population was limited to a certain
product line or class of
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FirstNameCorporation
Symantec LastNameGregory S. Clark
Comapany NameSymantec Corporation
April 8, 2019
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             revenue, please explain why.
             Clarify whether the number of potential transactions exposed to
the control deficiency
             in fiscal 2018 is indicative of what you might identify in a
typical year.
             Provide an analysis of the potential magnitude of additional
transactions, which
             includes the identified misstatement. In this regard, your
response indicates you
             excluded the misstatement in the analysis provided. In addition,
your analysis should
             consider the potential impact to income from continuing operations
before taxes,
             income from continuing operations, and net income, and how that
impacts your
             consideration of whether the identified adjustment rose to the
level of a material
             weakness. As part of this analysis, please explain whether the
additional potential
             magnitude determined was based on the full amount of revenue from
those
             transactions being deferred, or part of the amount being deferred.
If the latter, please
             explain the rationale.
3.       You state on page 69 that the Audit Committee noted relatively weak
and informal
         processes with respect to some aspects of review, approval and
tracking of transition and
         transformation expenses. Also, in the Form 8-K furnished on November
1, 2018 you refer
         to adjustments to stock-based compensation, certain other operating
expenses and income
         taxes. Tell us whether any adjustments related to each of these
matters relate to the
         revenue misstatement or to the related control deficiency. To the
extent these adjustments
         were separate from the revenue misstatement, please describe any
control deficiencies
         related to these adjustments, and tell us how you considered these
control deficiencies in
         aggregation with the other control deficiencies identified, including
the control deficiency
         related to the revenue misstatement. Lastly, tell us whether these
adjustments arose from
         control deficiencies impacting any of the COSO components outside of
control activities,
         including consideration related to aggregation of the control
deficiencies.
4.       Your disclosures on page 69 also indicate that the Audit Committee
identified certain
         behavior inconsistent with the company's Code of Conduct and related
policies. Please
         address the following related to that disclosure:

             Further describe the behaviors identified and the roles of the
individuals involved.
             Tell us whether any of those involved had financial reporting
responsibilities. If so,
             explain whether you identified any control deficiencies, including
with regards to the
             COSO components outside of control activities.
             Tell us whether the recent resignations of the Chief Operating
Officer and Chief
             Financial Officer were related to the Code of Conduct issues
and/or any other issues
             identified in the Audit Committee Investigation. If so, tell us
how that impacted your
             assessment of whether you identified any control deficiencies,
including with regards
             to the COSO components outside of control activities.
 Gregory S. Clark
Symantec Corporation
April 8, 2019
Page 4
             Describe further the clarifications and enhancements made to the
Code of Conduct and
             related policies. As part of your response, clarify whether other
control deficiencies
             were identified as part of the process of making these
enhancements. If so, please
             explain how these control deficiencies were considered in
aggregation with the other
             existing control deficiencies.

Form10-Q for the Quarter Ended December 28, 2018
Note 3. Revenues
Performance Obligations, page 10

5.       We note your response to prior comment 6. Considering the majority of
the arrangements
         that include a license and interrelated deliverables are term-based
licenses that are
         recognized over the contract term, please revise the table on page 11
to indicate as such.
       You may contact Brittany Ebbertt, Senior Staff Accountant, at
202-551-3572 or
Kathleen Collins, Accounting Branch Chief, at 202-551-3499 if you have
questions.



                                                              Sincerely,
FirstName LastNameGregory S. Clark
                                                              Division of
Corporation Finance
Comapany NameSymantec Corporation
                                                              Office of
Information Technologies
April 8, 2019 Page 4                                          and Services
FirstName LastName