TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo November 17, 2020 Richard Schlenker, Jr. Chief Financial Officer Exponent, Inc. 149 Commonwealth Drive Menlo Park, CA 94025 Re: Exponent, Inc. Form 10-K for the Fiscal Year Ended January 3, 2020 Filed February 28, 2020 File No. 000-18655 Dear Mr. Schlenker: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended January 3, 2020 Financial Statements Note 17. Segment Reporting, page 60 1. Please revise your footnote disclosure to discuss in greater detail the types of amounts included in the corporate operating expense, capital expenditures and depreciation and amortization line items of your segment reconciliations. Also, revise your management's discussion and analysis section to discuss the business reasons for changes between periods in each segment's operating income and amounts in the corporate operating expense line item. In circumstances where there is more than one business reason for the change, please quantify the incremental impact of each individual business reason discussed on the overall change in the line item. Refer to Item 303(a)(3) of Regulation S- K and SEC Release No. 33-8350. Richard Schlenker, Jr. Exponent, Inc. November 17, 2020 Page 2 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 Blaise Rhodes at 202-551-3774 or Rufus Decker at 202-551-3769 if you have questions. FirstName LastNameRichard Schlenker, Jr. Sincerely, Comapany NameExponent, Inc. Division of Corporation Finance November 17, 2020 Page 2 Office of Trade & Services FirstName LastName