December 20, 2024

C. Shane Smith
President and Chief Executive Officer
Smithfield Foods, Inc.
200 Commerce Street
Smithfield, VA 23430

       Re: Smithfield Foods, Inc.
           Amendment No. 2 to Draft Registration Statement on Form S-1
           Submitted December 13, 2024
           CIK No. 0000091388
Dear C. Shane Smith:

     We have reviewed your amended draft registration statement and have the
following
comment(s).

       Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our December 2, 2024 letter.

Amendment No. 2 to Draft Registration Statement on Form S-1 submitted December
13,
2024
General

1.     We note your revised disclosure that the selling shareholder in this
offering is SFDS
       UK Holdings Limited. Please revise your cover page and the principal and
selling
       shareholder section to identify the selling shareholder.
Lock-Up Agreements, page 175

2.     Please file the lock-up agreement described in this section as an
exhibit to your
       registration statement.
 December 20, 2024
Page 2

       Please contact Mindy Hooker at 202-551-3732 or Claire Erlanger at
202-551-3301 if
you have questions regarding comments on the financial statements and related
matters. Please contact Patrick Fullem at 202-551-8337 or Jennifer Angelini at
202-551-3047
with any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing
cc:   Colin Diamond