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CORRESP
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Correspondence

 Wachtell, Lipton, Rosen & Katz

 MARTIN LIPTON

 HERBERT M.
WACHTELL

 PAUL VIZCARRONDO, JR.

 PETER C. HEIN

HAROLD S. NOVIKOFF

 MEYER G. KOPLOW

THEODORE N. MIRVIS

 EDWARD D. HERLIHY

DANIEL A. NEFF

 ANDREW R. BROWNSTEIN

MICHAEL H. BYOWITZ

 PAUL K. ROWE

MARC WOLINSKY

 DAVID GRUENSTEIN

STEVEN A. ROSENBLUM

 STEPHANIE J. SELIGMAN

JOHN F. SAVARESE

 SCOTT K. CHARLES

JODI J. SCHWARTZ

 ADAM O. EMMERICH

GEORGE T. CONWAY III

 RALPH M. LEVENE

RICHARD G. MASON

 MICHAEL J. SEGAL

DAVID M. SILK

 ROBIN PANOVKA

DAVID A. KATZ

 ILENE KNABLE GOTTS

DAVID M. MURPHY

 JEFFREY M. WINTNER

TREVOR S. NORWITZ

 BEN M. GERMANA

ANDREW J. NUSSBAUM

 RACHELLE SILVERBERG

STEVEN A. COHEN

 DEBORAH L. PAUL

DAVID C. KARP

 RICHARD K. KIM

JOSHUA R. CAMMAKER

 MARK GORDON

JOSEPH D. LARSON

 LAWRENCE S. MAKOW

 51 WEST 52ND STREET

NEW YORK, N.Y. 10019-6150

TELEPHONE:        (212) 403 - 1000

 FACSIMILE:      (212) 403 -
2000

 _______________

GEORGE A. KATZ (1965-1989)

 JAMES H. FOGELSON (1967-1991)

 LEONARD M. ROSEN
(1965-2014)

 _______________

 OF COUNSEL

 JEANNEMARIE O’BRIEN

 WAYNE
M. CARLIN

 STEPHEN R. DiPRIMA

 NICHOLAS G. DEMMO

IGOR KIRMAN

 JONATHAN M. MOSES

T. EIKO STANGE

 DAVID A. SCHWARTZ

JOHN F. LYNCH

 WILLIAM SAVITT

ERIC M. ROSOF

 MARTIN J.E. ARMS

GREGORY E. OSTLING

 DAVID B. ANDERS

ANDREA K. WAHLQUIST

 ADAM J. SHAPIRO

NELSON O. FITTS

 JOSHUA M. HOLMES

DAVID E. SHAPIRO

 DAMIAN G. DIDDEN

ANTE VUCIC

 IAN BOCZKO

MATTHEW M. GUEST

 DAVID E. KAHAN

DAVID K. LAM

 BENJAMIN M. ROTH

JOSHUA A. FELTMAN

 ELAINE P. GOLIN

EMIL A. KLEINHAUS

 KARESSA L. CAIN

RONALD C. CHEN

 GORDON S. MOODIE

DONGJU SONG

 BRADLEY R. WILSON

GRAHAM W. MELI

 GREGORY E. PESSIN

CARRIE M. REILLY

 MARK F. VEBLEN

VICTOR GOLDFELD

 EDWARD J. LEE

BRANDON C. PRICE

 KEVIN S. SCHWARTZ

 WILLIAM T. ALLEN

PETER C. CANELLOS

 DAVID M. EINHORN

KENNETH B. FORREST

 THEODORE GEWERTZ

MAURA R. GROSSMAN

 RICHARD D. KATCHER

DOUGLAS K. MAYER

 ROBERT B. MAZUR

PHILIP MINDLIN

 ROBERT M. MORGENTHAU

 DAVID S. NEILL

BERNARD W. NUSSBAUM

 LAWRENCE B. PEDOWITZ

ERIC S. ROBINSON

 PATRICIA A. ROBINSON*

ERIC M. ROTH

 MICHAEL W. SCHWARTZ

ELLIOTT V. STEIN

 WARREN R. STERN

PATRICIA A. VLAHAKIS

 AMY R. WOLF

 * ADMITTED IN THE DISTRICT OF COLUMBIA

_______________

COUNSEL

 DAVID M. ADLERSTEIN

AMANDA K. ALLEXON

 LOUIS J. BARASH

DIANNA CHEN

 ANDREW J.H. CHEUNG

PAMELA EHRENKRANZ

KATHRYN GETTLES-ATWA

ADAM M. GOGOLAK

 PAULA N. GORDON

NANCY B. GREENBAUM

 MARK A. KOENIG

J. AUSTIN LYONS

 ALICIA C. McCARTHY

SABASTIAN V. NILES

 AMANDA N. PERSAUD

JEFFREY A. WATIKER

 September 11, 2015

FOIA CONFIDENTIAL TREATMENT REQUESTED BY

HEWLETT PACKARD ENTERPRISE COMPANY PURSUANT TO 17 C.F.R. 200.83

CERTAIN PORTIONS OF THIS LETTER HAVE BEEN OMITTED FROM THE

VERSION FILED VIA EDGAR. CONFIDENTIAL TREATMENT HAS BEEN

REQUESTED WITH RESPECT TO THE OMITTED PORTIONS. INFORMATION

THAT WAS OMITTED IN THE EDGAR VERSION HAS BEEN NOTED IN THE

EDGAR VERSION WITH A PLACEHOLDER IDENTIFIED BY THE MARK “[***]”.

VIA FEDEX AND EDGAR

 Ms. Barbara C.
Jacobs

 Assistant Director

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549

Re:
Hewlett Packard Enterprise Company

Amendment No. 1 to Registration Statement on Form 10

Filed August 10, 2015

File No. 001-37483

CONFIDENTIAL TREATMENT REQUESTED BY HEWLETT PACKARD ENTERPRISE COMPANY

HPE_0001

 Ms. Barbara C. Jacobs

U.S. Securities and Exchange Commission

 September 11, 2015

 Page
 2
 of 7

 Dear Ms. Jacobs:

On behalf of our client, Hewlett Packard Enterprise Company (the “Company”), we are providing the Company’s responses to
the comment of the Staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) set forth in your letter, dated September 2, 2015, with respect to
the filing referenced above (the “September 2, 2015 Comment Letter”). For the Staff’s convenience, the text of the Staff’s comment is set forth below in bold, followed by the Company’s response.

For reasons of business confidentiality, in a separate letter dated the date hereof, the Company has requested that certain confidential
information not be disclosed in response to any request made under the Freedom of Information Act or otherwise. Accordingly, pursuant to Rule 83 (17 C.F.R. 200.83) of the Rules of Practice of the Commission, a complete copy of this letter will be
provided only in paper form and not electronically as correspondence under the Commission’s EDGAR system. A redacted version, which excludes the confidential information, has been filed electronically on the Commission’s EDGAR system as
correspondence with the omitted information in the version filed via the EDGAR system identified by the mark “[***].”

 Management’s
Discussion and Analysis of Financial Condition and Results of Operations

 Critical Accounting Policies and Estimates

Goodwill, page 58

 We note
your response to prior comment 24 and your response to prior comment 1 from your letter dated June 9, 2015 relating to Hewlett Packard Company’s Form 10-K for the fiscal year ended October 31, 2014. However, based on our telephone
call with the company’s representatives on August 26, 2015, we understand that the EG segment manager reviews operating results information, including gross margins, for the business units included within the EG segment. Accordingly, for
those business units it appears that discrete financial information is available that is reviewed by the segment manager. The business units also appear to be businesses as defined in ASC 805-10-55-4 through 55-9. If so, it appears that the business
units within the EG segment represent components that are reporting units, as defined in ASC 350-20-35-34. Please clarify why you do not believe the business units represent components that are reporting units as defined by ASC 350-20-35-34 and ASC
350-20-55-1 to 5. Please also provide us with the reporting packages for the quarterly periods ended October 31, 2013 and January 31, 2014 that the EG segment manager reviewed in assessing operating results for the segment and each of the
business units discussed in the August 26, 2015 telephone call. If not otherwise evident, please quantify the corporate allocations included in the EG segment results that are not included in the business unit results. Also please describe the
types of the corporate costs allocated and which types constitute the significant portion of that allocation.

CONFIDENTIAL TREATMENT REQUESTED BY HEWLETT PACKARD ENTERPRISE COMPANY

HPE_0002

 Ms. Barbara C. Jacobs

U.S. Securities and Exchange Commission

 September 11, 2015

 Page
 3
 of 7

 Rule 83 confidential
treatment request made by Hewlett Packard Enterprise Company; Request Number 1.

 Response: The Company acknowledges that
the determination of reporting units under ASC 350-20-35-34 is a matter of significant judgment. In this response to the Staff’s comments will, the Company cover three points. First, the Company outlines its belief that these business units are
not components [***] and as such should not be considered discrete financial information. Second, the Company has also evaluated the guidance in ASC 350-20-35-35 and reached a conclusion that if the business units within EG were components, the
Company would conclude that the business units have similar economic characteristics such that they should be aggregated into one reporting unit. [***]

Discrete Financial Information Assessment

The Company respectfully advises the Staff that it believes the business units within its EG segment do not represent components that are
reporting units as defined by ASC 350-20-35-34 and ASC 350-20-55-1 to 5 [***] The Company interprets discrete financial information based upon its internal reporting structure. [***] Per the Staff’s request, the Company is supplementally
providing the Staff on a confidential basis with the reporting packages that the EG segment manager reviewed for the three months ended October 31, 2013 and January 31, 2014 referenced in the September 2, 2015 Comment Letter.

[***]

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CONFIDENTIAL TREATMENT REQUESTED BY HEWLETT PACKARD ENTERPRISE COMPANY

HPE_0003

 Ms. Barbara C. Jacobs

U.S. Securities and Exchange Commission

 September 11, 2015

 Page
 4
 of 7

Aggregation Assessment

As discussed on the Company’s August 26, 2015 call with the Staff, in the first quarter of fiscal 2014 the Company completed the
integration of the Company’s ESSN hardware-related business units with the TS business unit to align the Company’s product and service offerings with its go-to-market strategy. [***]

Given the subjectivity associated with determining what data constitutes discrete financial information, the Company had previously considered
whether the business units within ESSN met the aggregation criteria of ASC 350-20-35-35. In making this assessment, the Company first considered the aggregation criteria outlined in ASC 280-10-50-11 as discussed below. In addition, at the time the
Company made the changes to its reporting units in the first quarter of 2014, the Company contemporaneously analyzed the ESSN and TS reporting units included within EG to determine if they also met the aggregation criteria outlined in ASC 350. In
the following discussion, the Company has summarized how the aggregation criteria were initially considered with regard to ESSN and then subsequently how the criteria were reconsidered in the first quarter of fiscal year 2014 with regard to the
further aggregation of ESSN and TS.

 Before reviewing the Company’s application of the aggregation criteria outlined in ASC 350 and
ASC 280, the Company believes that providing the Staff with some background on its industry and the current trends could be beneficial. As discussed above and in response to the Staff’s prior comments, the Company merged its ESSN and TS
business in the first fiscal quarter of 2014. The merger of these two historical reporting units was done strategically, as industry trends and customer demands have been and are continuing to migrate from traditional IT purchases of standalone
devices toward integrated solutions. The Company’s major competitors are expanding their product and service offerings by further integrating their products and solutions. [***]

In determining that the business units within ESSN (if they were to represent components that are reporting units) and TS met the aggregation
criteria of ASC 350-20-35-35, the Company first considered the following aggregation criteria outlined in ASC 280-10-50-11. The guidance acknowledges that the aggregation of components for reporting unit identification is more qualitative than
quantitative and therefore not every factor needs to be met for components to qualify for aggregation:

1.
Similar long-term financial performance

 [***]

[***]

 [***]

2.
Nature of products and services

CONFIDENTIAL TREATMENT REQUESTED BY HEWLETT PACKARD ENTERPRISE COMPANY

HPE_0004

 Ms. Barbara C. Jacobs

U.S. Securities and Exchange Commission

 September 11, 2015

 Page
 5
 of 7

 In regards to
the nature of EG’s products and services, they are all similar in that they support the computer networking or infrastructure needs of enterprise customers. The EG portfolio has solutions for a variety of operating environments that address a
wide range of customer challenges. More frequently, customers are looking for integrated solutions that combine computing, storage, networking components and services. Customers want the server, storage and networking infrastructure simplified and
automated as much as possible. The business units within ESSN support and benefit each other as they develop products built on complementary technology platforms that more easily work together in a “plug and play” environment. [***]

3.
Nature of production processes

 [***]

4.
Type or class of customer for their products and services

 [***]

5.
Methods used to distribute their products or provide services

 All ESSN products and TS
maintenance contracts are sold in the same fashion through the previously described distribution channels. ESSN products (servers, storage and networking equipment) are purchased together with maintenance services (TS) to build technology
infrastructure for the Company’s customers. As part of the integration of the business units in the first quarter of fiscal 2014, [***]

The Company notes that while ASC 350-20-55-7 requires consideration of the above factors outlined in ASC 280-10-50-11, it also indicates that
every factor need not be met in order for two components to be considered economically similar. Additionally, management considered the following four additional criteria outlined in ASC 350-20-55-7:

(i)
The manner in which an entity operates its business and the nature of those operations

 As
discussed on the Company’s call with the Staff on August 26, 2015 [***]

(ii)
Whether goodwill is recoverable from the separate operations of each component business or from two or more component businesses working in concert (which might be the case if the components are economically
interdependent)

 [***]

(iii)
The extent to which the component businesses share assets and other resources, as might be evidenced by transfer pricing mechanisms

CONFIDENTIAL TREATMENT REQUESTED BY HEWLETT PACKARD ENTERPRISE COMPANY

HPE_0005

 Ms. Barbara C. Jacobs

U.S. Securities and Exchange Commission

 September 11, 2015

 Page
 6
 of 7

 [***]

(iv).
Whether components support and benefit from common research and development projects

 The
Company’s research and development efforts are focused on designing and developing products, services and solutions that anticipate customers’ changing needs and desires and emerging technological trends. [***]

Historical Financial Statements Assessment

[***]

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Conclusion

 The
Company respectfully advises the Staff that for the reasons described above it does not believe the business units within the EG segment represent components that are reporting units, as defined in ASC 350-20-35-34. The Company does however
acknowledges that the application of this guidance involves significant judgment and could result in the Staff reaching a different conclusion. As a result, the Company has also evaluated whether it would be appropriate to aggregate such components
for purposes of determining its reporting units in accordance with ASC 350-20-35-35 and ASC 280-10-50-11. The Company previously updated its assessment contemporaneously with the integration of ESSN and TS and concluded that there is a compelling
rationale that they should be aggregated, for the reasons described above. [***]

 The Company is supplementally and on a confidential
basis providing the Staff with the reporting packages for the three months ended October 31, 2013 and January 31, 2014 referenced in the September 2, 2015 Comment Letter (the “Supplemental Information”). The
Supplemental Information is being provided to the Staff under separate cover on a confidential and supplemental basis pursuant to Rule 12b-4 under the Exchange Act. In accordance with such Rule, the Company hereby requests that such materials be
destroyed or returned promptly to us following completion of the Staff’s review thereof. By separate letter, the Company has requested confidential treatment of the Supplemental Information pursuant to the provisions of 17 C.F.R. § 200.83.

 The Company requests that the information contained in Request Number 1 be treated as confidential information and that the Commission provide timely
notice to the undersigned before it permits an