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		Exhibit

April 15, 2020

Division of Corporation Finance

United States Securities and Exchange Commission

Washington, D.C. 20549

Attn: Suying Li / Angela Lumley, Office of Trade & Services

Re:

 Hewlett Packard Enterprise Company

Item 2.02 Form 8-K dated March 3, 2020

File No. 001-37483

Dear Mses. Li and Lumley:

Hewlett Packard Enterprise Company (“HPE,” the “Company” or “we”) hereby sets forth the following information in response to the comments contained in the correspondence of the staff of the Securities and Exchange Commission (the “Staff”), dated April 10, 2020, relating to our Current Report on Form 8-K, filed March 3, 2020. We have set forth below the comment received by the Staff, as well as the Company’s response thereto.

Item 2.02 Form 8-K dated March 3, 2020

Exhibit 99.1, page 1

1. Please revise your disclosure to provide a quantitative reconciliation for your non-GAAP gross margin and free cash flow to their most directly comparable GAAP financial measures as required by Item 10(e)(1)(i)(B) of Regulation S-K.

Response:   We acknowledge the Staff’s comment regarding GAAP to non-GAAP reconciliations in connection with our earnings release furnished on Form 8-K filed March 3, 2020.  We have expanded the reconciliation tables provided in connection with such earnings release to include quantitative reconciliations of non-GAAP gross margin to GAAP gross margin and free cash flow to cash flow from operations.  A draft of these expanded reconciliation tables is attached hereto as Attachment A.  We will include these reconciliations with respect to the three months ended January 31, 2020 in the tables accompanying our earnings release to be published with respect to the fiscal quarter ended April 30, 2020, which will be furnished on Form 8-K.   We confirm that future discussions of non-GAAP gross margin and free cash flow will be accompanied by quantitative reconciliations to their most directly comparable GAAP financial measures.

Sincerely,

/s/ Tarek Robbiati

Tarek Robbiati

Chief Financial Officer

6280 America Center Drive

San Jose, CA 95002

hpe.com

Attachment A

HEWLETT PACKARD ENTERPRISE COMPANY AND SUBSIDIARIES

 ADJUSTMENTS TO GAAP NET EARNINGS, EARNINGS FROM OPERATIONS, OPERATING PROFIT MARGIN,

GROSS PROFIT, GROSS PROFIT MARGIN, CASH FLOW FROM OPERATING ACTIVITIES AND

DILUTED NET EARNINGS PER SHARE
(Unaudited)
(In millions, except percentages and per share amounts)

 Three months ended January 31, 2020

 Diluted net  earnings per share

 Three months ended
October 31, 2019

 Diluted net earnings per share

 Three months ended January 31, 2019

 Diluted net earnings per share

GAAP net earnings

 $

 333

 $

 0.25

 $

 480

 $

 0.36

 $

 177

 $

 0.13

Non-GAAP adjustments:

Amortization of initial direct costs

 3

 —

 —

 —

 —

 —

Amortization of intangible assets

 120

 0.09

 68

 0.05

 72

 0.05

Transformation costs

 89

 0.07

 151

 0.11

 78

 0.06

Acquisition, disposition and other related charges(1)

 42

 0.03

 54

 0.04

 63

 0.04

Tax indemnification adjustments

 21

 0.02

 (288

 )

 (0.22

 )

 (219

 )

 (0.16

 )

Non-service net periodic benefit credit

 (37

 )

 (0.03

 )

 (14

 )

 (0.01

 )

 (16

 )

 (0.01

 )

Loss from equity interests

 37

 0.03

 38

 0.03

 38

 0.03

Adjustments for taxes

 (33

 )

 (0.02

 )

 155

 0.13

 397

 0.28

Non-GAAP net earnings

 $

 575

 $

 0.44

 $

 644

 $

 0.49

 $

 590

 $

 0.42

GAAP earnings from operations

 $

 348

 $

 460

 $

 456

Non-GAAP adjustments

Amortization of initial direct costs

 3

 —

 —

Amortization of intangible assets

 120

 68

 72

Transformation costs

 89

 151

 78

Acquisition, disposition and other related charges(1)

 42

 54

 63

Non-GAAP earnings from operations

 $

 602

 $

 733

 $

 669

GAAP operating profit margin

 5

 %

 6

 %

 6

 %

Non-GAAP adjustments

 4

 %

 4

 %

 3

 %

Non-GAAP operating profit margin

 9

 %

 10

 %

 9

 %

GAAP Net revenue

 $

 6,949

 $

 7,215

 $

 7,553

GAAP cost of sales

 4,667

 4,822

 5,207

GAAP gross profit

 $

 2,282

 $

 2,393

 $

 2,346

Non-GAAP adjustments

Amortization of initial direct costs

 $

 3

 $

 —

 $

 —

Acquisition, disposition and other related charges(1)

 20

 7

 —

Non-GAAP gross profit

 $

 2,305

 $

 2,400

 $

 2,346

GAAP gross profit margin

 32.8

 %

 33.2

 %

 31.1

 %

Non-GAAP adjustments

 0.4

 %

 0.1

 %

 —

 %

Non-GAAP gross profit margin

 33.2

 %

 33.3

 %

 31.1

 %

Net cash (used in) provided by operating activities

 $

 (79

 )

 $

 1,432

 $

 382

Investment in property, plant and equipment

 (568

 )

 (703

 )

 (729

 )

Proceeds from sale of property, plant and equipment

 462

 149

 157

Free cash flow

 $

 (185

 )

 $

 878

 $

 (190

 )

(1) Three months ended January 31, 2020 and October 31, 2019 includes Acquisition, disposition and other related charges of $20 million and $7 million, respectively, related to a non-cash inventory fair value adjustment in connection with the acquisition of Cray, Inc., which was included in Cost of Sales.