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SEC Comment Letter for Lumentum Holdings Inc. (LITE) (CIK 0001633978) (LITE) — Feb 8, 2017

Lumentum Holdings Inc. (LITE) (CIK 0001633978)
Date: Feb. 8, 2017 · CIK: 0001633978 · Accession: 0000000000-17-004462

Regulatory Compliance Financial Reporting Business Model Clarity

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File numbers found in text: 001-36861

Referenced dates: January 17, 2017

Date
February 8, 2017
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
Lumentum Holdings Inc. (LITE) (CIK 0001633978)

Letter

Mail Stop 4628 February 8, 2017 Via E -mail Aaron Tachibana Chief Financial Office r Lumentum Holdings Inc . 400 North McCarthy Boulevard Milpitas, CA 95035

Re: Lumentum Holdings, Inc. 10-K for Fiscal Year Ended July 2, 2016 Filed September 2, 2016 File No. 001-36861

Dear Mr. Tachibana :

We refer you to our comment letter dated January 17, 2017 , regarding business contacts with Sudan and Syria. We have completed our review of this subject matter. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, com ments, action or absence of action by the staff.

Sincerely,
/s/ Cecilia Blye

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Mail Stop 4628

February 8, 2017

Via E -mail
Aaron Tachibana
Chief Financial Office r
Lumentum Holdings Inc .
400 North McCarthy Boulevard
Milpitas, CA 95035

Re: Lumentum  Holdings, Inc.
10-K for Fiscal Year  Ended July 2, 2016
 Filed September 2, 2016
 File No. 001-36861

Dear Mr. Tachibana :

We refer you to our comment letter dated January 17, 2017 , regarding business contacts
with Sudan and Syria.  We have completed our review of this subject matter.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, com ments, action or absence of action by the staff.

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  Larry Spirgel
  Assistant Director
 Division of Corporation Finance

Judy Hamel
General Counsel
Lumentum Holdings Inc.