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May 4, 2020
Michael Nefkins
Chief Executive Officer
Resideo Technologies, Inc.
901 E 6th Street
Austin, Texas 78702
Re:Resideo Technologies, Inc.
Form 8-K
Filed February 26, 2020
File No. 1-38635
Dear Mr. Nefkins:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may 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 February 26, 2020
Exhibit 99, page 1
1.We note your disclosure of Adjusted EBIDTA, a non-GAAP financial measure, precedes
your disclosure of Net Income or Loss, the most directly comparable GAAP
measure.  Item 10(e)(1)(i)(A) of Regulation S-K requires that when a non-GAAP measure
is presented the most directly comparable GAAP measure should be presented with equal
or greater prominence.  Please revise your presentation in future earnings releases
accordingly.
            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 Tony Watson at (202) 551-3318 or Bill Thompson at (202) 551-
3344 with any questions.

 FirstName LastNameMichael  Nefkins
 Comapany NameResideo Technologies, Inc.
 May 4, 2020 Page 2
 FirstName LastName
Michael  Nefkins
Resideo Technologies, Inc.
May 4, 2020
Page 2
Sincerely,
Division of Corporation Finance
Office of Trade & Services