SecProbe.io

March 31, 2020
Craig A. Lampo
Senior Vice President and Chief Financial Officer
Amphenol Corporation
358 Hall Avenue
Wallingford, Connecticut 06492
Re:Amphenol Corporation
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 12. 2020
File No. 001-10879
Dear Mr. Lampo:
            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 December 31, 2019
Notes to Consolidated Financial Statements
Note 13 - Reportable Business Segments and International Operations, page 74
1.We note your disclosure that the Company has two reportable business segments:
(i) Interconnect Products and Assemblies and (ii) Cable Products and Solutions.  We also
note your disclosure that the Company organizes its reportable business segments based
on similar economic characteristics and business groupings of products, services, and
customers.  Please tell us, and clarify in future filings, whether you are aggregating
operating segments into your Interconnect Products and Assemblies reportable segment as
required by ASC 280-10-50-2.  If you are aggregating operating segments, please also
address the following:

•Identify your operating segments;

 FirstName LastNameCraig A. Lampo
 Comapany NameAmphenol Corporation
 March 31, 2020 Page 2
 FirstName LastName
Craig A. Lampo
Amphenol Corporation
March 31, 2020
Page 2
•Demonstrate to us how you determined your aggregation of operating segments
complies with the requirements of ASC 280-10-50-11, including how you concluded
they exhibit similar economic characteristics; and

•Explain to us how you determined you have two reporting units for goodwill
impairment testing based on the requirements of ASC 350-20.
2.We note you identify eight primary end markets in your Business Section including:
Automotive; Broadband Communications; Commercial Aerospace; Industrial;
Information Technology and Data Communications; Military; Mobile Devices; and
Mobile Networks.  We also note you identify eight operating groups on your website
including: Military and Aerospace; Automotive Products; Industrial Products; Mobile
Consumer Products; Interconnect and Sensor Systems; Information Communications and
Commercial Products; RF, Optics and Broadband; and Sensor Technology and your
Management Team identifies Senior Vice Presidents and Group General Managers or
Vice Presidents and Group General Managers for each operating group.  Please address
the following:

•Explain to us how your operating groups are reflected in your reportable segments;

•Tell us how you assessed whether each operating group is an operating segment as
defined in ASC 280-10-50-1 and explain to us the nature and extent of the discrete
financial information available for operating groups.  If you have determined that
your operating groups are not operating segments, fully explain to us how you made
that determination;

•Identify your CODM and explain to us how that determination was made; and

•Describe the nature and extent of the financial information reviewed by the CODM to
assess performance and allocate resources.
            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 Andi Carpenter at 202-551-3645 or Anne McConnell at 202-551-
3709 if you have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Manufacturing