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March 15, 2023
Tarek Robbiati
Chief Financial Officer
Hewlett Packard Enterprise Company
1701 East Mossy Oaks Rd.
Spring, TX 77389
Re:Hewlett Packard Enterprise Company
Form 10-K for Fiscal Year Ended October 31, 2022
Filed December 8, 2022
File No. 001-37483
Dear Tarek Robbiati:
            We have limited our review of your filing to the financial statements and related
disclosures 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 Fiscal Year Ended October 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Fiscal Year 2022 Compared to Fiscal Year 2021
Segment Information, page 45
1.Please quantify the extent to which changes in net revenue and income from operations
are attributable to changes in prices or to changes in the volume or amount of goods or
services being sold, or to the introduction of new products or services.  Please also revise
to quantify factors to which changes are attributed. For example, we note your disclosure
that sales were impacted by higher prices, offset by unfavorable currency fluctuations and
lower shipments.   Refer to Item 303(b)(2)(iii) of Regulation S-K.

 FirstName LastNameTarek Robbiati
 Comapany NameHewlett Packard Enterprise Company
 March 15, 2023 Page 2
 FirstName LastName
Tarek Robbiati
Hewlett Packard Enterprise Company
March 15, 2023
Page 2
GAAP to Non-GAAP Reconciliations
Reconciliation of GAAP earnings from operations and operating profit margin to non-GAAP
earnings from operations and operating profit margin, page 54
2.Refer to your reconciliations of non-GAAP earnings from operations and net earnings.
Please explain why it is appropriate to adjust for transformation costs.  We note from your
disclosure in footnote 3 to the financial statements that you have incurred transformation
costs in each of the last three fiscal years.  We note from your Form 10-K for the year
ended October 31, 2019 that you also incurred such costs in each of the preceding three
years as well.  In this regard, these costs appear to be normal, recurring operating
expenses for your business.  Refer to Question 100.01 of the Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures.
Non-GAAP Financial Measures, page 56
3.You disclose that management believes excluding items from non-GAAP financial
measures facilitates a "more meaningful" evaluation of your current operating
performance in comparison to our peers.  Please revise your disclosure of usefulness of
non-GAAP measures to investors to (a) eliminate descriptive language suggesting non-
GAAP financial measures are “more meaningful” than comparable GAAP measures and
(b) ensure that the disclosure addresses each non-GAAP measure and explains why each
measure is useful to investors in terms that are substantive and specific to you (e.g.,
“investors should use this measure to…” or “this measure tells investors…”).  Refer to
Item 10(e)(1)(i)(C) of S-K and footnote 44 to FR-65.  Note that disclosure of
management’s use of such measures is only necessary to the extent material to investors.
Notes to Consolidated Financial Statements
Note 1: Overview and Summary of Significant Accounting Policies
Revenue Recognition, page 69
4.We note your disclosure of revenue on a segment and geographical basis pursuant to ASC
280.  Please tell us your consideration of providing disaggregated disclosure of revenues.
Refer to Refer to ASC 606-10-50-5 to 50-6 and 55-89 to 55-91.  In this regard, we note
that you provide a number of distinct products and services and that you disclose
Annualized Revenue Run-rate ("ARR") as your pivot to as-a-service continues.
Note 17: Litigation and Contingencies, page 119
5.A large portion of your disclosure is dedicated to providing the history of the legal
proceedings in various cases in which you are involved, including the dates of various
motions, appeals, and hearings.  In addition, your disclosure includes legalese, including
statements such as: “demurrer,” “show cause notices,” “certify a Rule 23 class,”
“remittitur,” and “remand.”  Please consider whether it would be useful to investors to
place more emphasis on the current status the cases, in plain English, rather than on the

 FirstName LastNameTarek Robbiati
 Comapany NameHewlett Packard Enterprise Company
 March 15, 2023 Page 3
 FirstName LastName
Tarek Robbiati
Hewlett Packard Enterprise Company
March 15, 2023
Page 3
history of legal proceedings.
            In closing, 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 Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services