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SEC Comment Letter for Science Applications International Corp (SAIC) (CIK 0001571123) (SAIC) — Feb 9, 2021

Science Applications International Corp (SAIC) (CIK 0001571123)
Date: Feb. 9, 2021 · CIK: 0001571123 · Accession: 0000000000-21-001612

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File numbers found in text: 001-35832

Date
February 9, 2021
Author
Office of Technology
Form
UPLOAD
Company
Science Applications International Corp (SAIC) (CIK 0001571123)

Letter

United States securities and exchange commission logo February 9, 2021 Prabu Natarajan Chief Financial Officer Science Applications International Corporation 12010 Sunset Hills Road Reston, VA 20190 Re:Science Applications International Corp Form 10-K for the Year Ended January 31, 2020 Filed March 27, 2020 Form 8-K Filed December 3, 2020 File No. 001-35832 Dear Mr. Natarajan: We have reviewed your February 3, 2021 response to our comment letter and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 8-K filed December 3, 2020 SAIC Announces Third Quarter of Fiscal Year 2021 Results Fiscal Year 2021 Guidance, page 4 1.To the extent that you provide earnings guidance which includes non-GAAP measures, please comply with the guidance in the penultimate bullet of Q&A 102.10 of the CD&I on Non-GAAP Financial Measures (April 4, 2018) in future filings of your Form 8-K.

FirstName LastNamePrabu Natarajan Comapany NameScience Applications International Corporation February 9, 2021 Page 2 FirstName LastName Prabu Natarajan Science Applications International Corporation February 9, 2021 Page 2 You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding this comment and related matters. Please contact Edwin Kim, Staff Attorney at (202) 551-3297 or Larry Spirgel, Office Chief at (202) 551-3815 with any other questions. Sincerely, Division of Corporation Finance Office of Technology

Show Raw Text
United States securities and exchange commission logo
February 9, 2021
Prabu Natarajan
Chief Financial Officer
Science Applications International Corporation
12010 Sunset Hills Road
Reston, VA 20190
Re:Science Applications International Corp
Form 10-K for the Year Ended January 31, 2020
Filed March 27, 2020
Form 8-K Filed December 3, 2020
File No. 001-35832
Dear Mr. Natarajan:
            We have reviewed your February 3, 2021 response to our comment letter and have the
following comment.  In our comment, we ask you to provide us with information so we may
better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 8-K filed December 3, 2020
SAIC Announces Third Quarter of Fiscal Year 2021 Results
Fiscal Year 2021 Guidance, page 4
1.To the extent that you provide earnings guidance which includes non-GAAP measures,
please comply with the guidance in the penultimate bullet of Q&A 102.10 of the CD&I on
Non-GAAP Financial Measures (April 4, 2018) in future filings of your Form 8-K.

 FirstName LastNamePrabu  Natarajan
 Comapany NameScience Applications International Corporation
 February 9, 2021 Page 2
 FirstName LastName
Prabu  Natarajan
Science Applications International Corporation
February 9, 2021
Page 2
            You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or
Robert Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding
this comment and related matters.  Please contact Edwin Kim, Staff Attorney at (202) 551-3297
or Larry Spirgel, Office Chief at (202) 551-3815 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology