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seccommentletterresponse

                                      Todd Taylor  Vice President and Principal Accounting Officer  1025 West NASA Boulevard   Melbourne, FL  32919    Via Electronic Submission (Correspondence)                                                                    March 27, 2020  Heather Clark  Office of Manufacturing  Division of Corporation Finance  Securities and Exchange Commission  100 F Street, N.E.  Washington, D.C. 20549          Re:   L3Harris Technologies, Inc.              Form 10-K for the Fiscal Year ended June 28, 2019              Form 8-K furnished October 30, 2019              File No. 001-03863    Dear Ms. Clark:       Reference is made to your letter (the “Comment Letter”) dated January 21, 2020 containing  comments of the Staff of the Division of Corporation Finance (the “Staff”) of the U.S.  Securities and Exchange Commission (the “Commission”) on L3Harris Technologies, Inc.’s  (“L3Harris” or the “Company”) Form 8-K furnished on October 30, 2019.  On behalf of  L3Harris, I submit this letter in response to the comments included in the Comment Letter.             For reference purposes, the text of the Staff’s two numbered comments Comment Letter is  set forth below in bold, followed by our response thereto.          Staff Comment:    Form 8-K furnished October 30, 2019    Exhibit 99.1, page 1       1. We note your presentation of “combined” results and your disclosure that such        information is not prepared in accordance with Article 11 of Regulation S-X. In        this regard, it is unclear why you believe that the supplemental unaudited        combined financial information is meaningful to an investor, considering that it        excludes pro forma adjustments calculated under Article 11 of Regulation S-X. It        also appears the presentation could be confusing to an investor. In this regard,        please tell us how the supplemental unaudited combined financial information        compares to amounts calculated in accordance with Article 11 of Regulation S-X.

Ms. Heather Clark  Securities and Exchange Commission  March 27, 2020  Page 2      L3Harris Response:      As agreed during our telephone conversations, L3Harris’ future earnings releases that  include results for periods prior to the merger involving L3 Technologies, Inc. and Harris  Corporation (the “L3Harris Merger”), which closed on June 29, 2019, also will include for  those periods pro forma financial information consistent with Article 11 of Regulation S-X.            2. We note your disclosure that the supplemental unaudited combined financial        information does not give effect to the L3Harris merger under the acquisition        method of accounting in accordance with ASC 805. Considering that the        information does not give effect to ASC 805, it appears that the resulting non        GAAP measures substitute individually tailored measurement methods for those        of GAAP and could violate Rule 100(b) of Regulation G.  Please tell us how you        considered Question 100.04 of the SEC Staff's Compliance & Disclosure        Interpretations last updated April 4, 2018.   L3Harris Response:          Consistent with the response to Comment #1 above, L3Harris’ future earnings releases will  not include unaudited combined financial information that does not give effect to the L3Harris  Merger under the acquisition method of accounting in accordance with ASC 805.                  If you have any questions, please do not hesitate to contact me at (321) 724-3536.                                     Very truly yours,                                      /s/ Todd Taylor                                   Todd Taylor                                   Vice President and Principal Accounting Officer      cc: Christy Adams, Securities and Exchange Commission     Claire Erlanger, Securities and Exchange Commission     Jay Malave, Senior Vice President and Chief Financial Officer, L3Harris     Scott T. Mikuen, Senior Vice President, General Counsel and Secretary, L3Harris     Robert A. Johnson Jr., Vice President, Associate General Counsel, L3Harris