United States securities and exchange commission logo June 26, 2023 Elizabeth Eby Chief Financial Officer Sunpower Corporation 1414 Harbour Way South , Suite 1901 Richmond , California 94804 Re: Sunpower Corporation Form 10-K for the year ended January 1, 2023 Form 10-Q for the period ended April 2, 2023 Form 8-K furnished May 3, 2023 Response dated June 16, 2023 File No. 1-34166 Dear Elizabeth Eby: We have reviewed your June 16, 2023 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our June 1, 2023 letter. Correspondence dated June 16, 2023 Form 10-Q for the period ended April 2, 2023 Item 5: Other Information Information concerning certain limited activities related to Iran, page 40 1. We note your response to our prior comment 1 that you will respond by June 30, 2023. We will evaluate your response when provided. Form 8-K furnished May 3, 2023 Exhibit 99.1 Earnings Release Reconciliations of GAAP Measures to Non-GAAP Measures, page 14 Elizabeth Eby Sunpower Corporation June 26, 2023 Page 2 2. We note your response to our comment number 2. In future filings, please revise to remove the adjustments for general operating results of business divestitures that did not meet the criteria for discontinued operations, such as the Hillsboro facility. As noted in our prior comment, excluding normal operating costs related to businesses that do not meet the criteria for being presented as discontinued operations pursuant to ASC 205-20, would represent individually tailored accounting measures. Refer to Question 100.04 of the Non-GAAP Compliance and Disclosure Interpretations. Additionally, the true-up to warranty claims appears to be a continuing obligation of the company, and to the extent it is recorded in cost of sales, appears to represent normal cash operating expenses which should not be adjusted from these Non-GAAP measures. Please revise your Non-GAAP measures in future filings. You may contact Charles Eastman at (202) 551-3794 or Claire Erlanger at (202) 551- 3301 with any questions. FirstName LastNameElizabeth Eby Sincerely, Comapany NameSunpower Corporation Division of Corporation Finance June 26, 2023 Page 2 Office of Manufacturing FirstName LastName