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United States securities and exchange commission logo
February 9, 2021
Prabu Natarajan
Chief Financial Officer
Science Applications International Corporation
12010 Sunset Hills Road
Reston, VA 20190
Re: Science
Applications International Corp
Form 10-K for the
Year Ended January 31, 2020
Filed March 27,
2020
Form 8-K Filed
December 3, 2020
File No. 001-35832
Dear Mr. Natarajan:
We have reviewed your February 3, 2021 response to our comment
letter and have the
following comment. In our comment, we 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 December 3, 2020
SAIC Announces Third Quarter of Fiscal Year 2021 Results
Fiscal Year 2021 Guidance, page 4
1. To the extent that you
provide earnings guidance which includes non-GAAP measures,
please comply with the
guidance in the penultimate bullet of Q&A 102.10 of the CD&I on
Non-GAAP Financial
Measures (April 4, 2018) in future filings of your Form 8-K.
Prabu Natarajan
Science Applications International Corporation
February 9, 2021
Page 2
You may contact Kathryn Jacobson, Senior Staff Accountant at (202)
551-3365 or
Robert Littlepage, Accountant Branch Chief at (202) 551-3361 if you have
questions regarding
this comment and related matters. Please contact Edwin Kim, Staff Attorney at
(202) 551-3297
or Larry Spirgel, Office Chief at (202) 551-3815 with any other questions.
FirstName LastNamePrabu Natarajan Sincerely,
Comapany NameScience Applications International Corporation
Division of Corporation
Finance
February 9, 2021 Page 2 Office of Technology
FirstName LastName