August 23, 2019

Christopher Collier
Chief Financial Officer
FLEX LTD.
2 Changi South Lane
Singapore 486123

        Re: FLEX LTD.
            Form 10-K for the Fiscal Year Ended March 31, 2019
            Filed on May 21, 2019
            Form 8-K Furnished on July 25, 2019
            File No. 000-23354

Dear Mr. Collier:

       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 March 31, 2019

Risk Factors
We are subject to risks relating to litigation and regulatory
investigations..., page 19

1.     You disclose that on February 14, 2019, you submitted an initial
notification of voluntary
       disclosure to the U.S. Department of Treasury, Office of Foreign Assets
Control regarding
       possible non-compliance with U.S. sanctions requirements. Please tell us
whether the
       activities underlying your submission involve Syria, Sudan or North
Korea, countries
       which are designated by the U.S. Department of State as state sponsors
of terrorism and
       are subject to U.S. economic sanctions and/or export controls. If so,
please describe to us
       the nature and extent of any past, current, and anticipated contacts
with Syria, Sudan and
       North Korea, including contacts with those countries' governments,
whether through
       subsidiaries, distributors, customers, affiliates, or other direct or
indirect arrangements.
 Christopher Collier
FirstName LastNameChristopher Collier
FLEX LTD.
Comapany NameFLEX LTD.
August 23, 2019
August 23, 2019 Page 2
Page 2
FirstName LastName



2.       On page 11 of your 10-K for the fiscal year ended March 31, 2018, you
identified Huawei
         as a key customer in your CEC segment. Huawei and some its affiliates
appear on the
         U.S. Department of Commerce's Entity List because of certain
activities with Iran, which
         is also designated as a state sponsor of terrorism. Recent articles
have discussed this ban
         on Huawei and its impact on you, including several articles that
attributed a reduction in
         your workforce in China to this ban. A transcript of a June Bank of
America Merrill
         Lynch Global Technology Conference quotes an analyst as stating that
the bank has been
         getting investor questions about Huawei and its impact on you. Please
discuss the
         potential for reputational harm from your relationship with Huawei. In
this regard, we
         note that recent news articles have reported that Huawei may have
secretly helped the
         North Korean government build its commercial wireless network, which
it may have used
         to spy on people, and that helping to build the network may have
violated U.S. export
         controls.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources
Free Cash Flow, page 47

3.       Please revise to label the measure "adjusted free cash flow." We refer
you to Question
         102.07 of the Compliance and Disclosure Interpretations for Non-GAAP
Financial
         Measures. Similar concerns apply to your earnings releases furnished
on Form 8-K and to
         the presentations on your website.
Form 8-K Furnished on July 25, 2019

Exhibit 99.1

4.       Your presentation of the "adjusted net cash provided by operating
activities" subtotal in
         your reconciliation to free cash flow implies that collections of
deferred purchase price
         receivables are operating rather than investing cash flows. This
results in a commingling
         of operating and investing cash flow results, which may not comply
with Regulation G.
         Accordingly, please remove this subtotal from your reconciliation as
well as all related
         references to it in your narrative. Similar concerns apply to the
earnings release slide
         decks and summary financials schedules on your website.
5.       We note your presentation of Free Cash Flow Conversion in your summary
financials
         schedules on your website. Please revise to also present this measure
on a GAAP basis in
         accordance with Rule 100(a) of Regulation G.
 Christopher Collier
FLEX LTD.
August 23, 2019
Page 3


        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 Frank Knapp, Staff Accountant, at (202) 551-3405 or
Christine Dietz,
Assistant Chief Accountant, at (202) 551-3408 if you have any questions.



                                                          Sincerely,
FirstName LastNameChristopher Collier
                                                          Division of
Corporation Finance
Comapany NameFLEX LTD.
                                                          Office of Information
Technologies
August 23, 2019 Page 3                                    and Services
FirstName LastName