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May 23, 2024
Matthew Galvanoni
Chief Financial Officer
Pilgrim’s Pride Corporation
1770 Promontory Circle
Greeley, CO 80634-9038
Re:Pilgrim’s Pride Corporation
Annual Report on Form 10-K for the Year Ended December 31, 2023
Filed February 27, 2024
File No. 001-09273
Dear Matthew Galvanoni:
            We have reviewed your filing and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations 2023 Compared to 2022, page 24
1.We note that your discussion of changes in results of operations attributes the increases
and decreases in changes in revenue and cost of sales to sales volume and sales per pound.
To further enhance investor understanding, for each of your three reportable
segments, please consider revising future filings to include a table that discloses the
quantity (or volume) of pounds or tons sold, along with a range of the commodity prices.
Note 2. Revenue Recognition, page 56
2.Refer to the table of disaggregated revenue in Note 2. We note from your disclosures here
and in Note 20, that you disclose disaggregated revenue by segments, as well as by the
product lines Fresh, Prepared, Export and Other, and customer locations. We note from
your earnings calls that you also discuss revenue in terms of "case ready," "big bird," and
"small bird" as well as by distribution channels. Please consider revising future filings to
provide additional disaggregation of your revenue by sales or distribution channels, such

 FirstName LastNameMatthew Galvanoni
 Comapany NamePilgrim’s Pride Corporation
 May 23, 2024 Page 2
 FirstName LastName
Matthew Galvanoni
Pilgrim’s Pride Corporation
May 23, 2024
Page 2
as retailers, foodservice, restaurants, and export markets, and/or additional product
categories. Reference is also made to your discussion on page 2 under Market Overview,
and the description of each segment's distribution channel as disclosed in Note 20. Your
response should give consideration to ASC 606-10-55-89 through 55-91.
Note 21. Commitments and Contingencies
Litigation, page 86
3.For those legal proceedings which are disclosed and exposure to loss exists in excess of
the amount accrued, or no accrual has been made, please revise future filings to ensure
that an estimate of the possible loss or range of loss is disclosed or a statement that such
an estimate cannot be made. For example, you disclose that you continue to litigate certain
class actions in the Oklahoma Court and Colorado Court, but the disclosure does not
include any related dollar amounts of accrual, or estimated loss, or a statement that you
cannot make such an estimate. Please revise future filings accordingly. See guidance in
ASC 450-20-50-3 and 50-4.
General
4.We note that your Form 8-K filed on May 1, 2024, reports that shareholders approved the
appointment of Joesley and Wesley Batista to your board of directors. Please revise
applicable future filings to include appropriate risk factors and a discussion of the civil
and criminal actions and investigations related to your ultimate controlling shareholders,
consistent with disclosure appearing on pages 10-12 and 125-27 of the Form 20-F filed by
your parent company, JBS S.A.
            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.
            Please contact Beverly Singleton at 202-551-3328 or Claire Erlanger at 202-551-3301 if
you have questions regarding comments on the financial statements and related matters. Please
contact Jennifer Angelini at 202-551-3047 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Jeffrey Sherman