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United States securities and exchange commission logo
January 4, 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 10-Q for the
Quarter Ended October 30, 2020
Filed December 4,
2020
File No. 001-35832
Dear Mr. Natarajan:
We have reviewed your filing 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 10-Q for the Quarter Ended October 30, 2020
Item 2. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Impacts of the COVID-19 Pandemic, page 22
1. We note the CARES Act
provides a mechanism to recover your labor costs where your
employees are ready and
able to work but unable to access required facilities due to
COVID-19. If you
received any assistance under the CARES Act (including but not
limited to Section 3610
thereunder to keep your employees and subcontractors in a ready
state), please quantify
and disclose the short and long-term impact of that assistance on
your financial
condition, results of operations, liquidity and capital resources. Refer to CF
Disclosure Guidance:
Topic No. 9A - Coronavirus (COVID-19) Disclosure
Considerations
Regarding Operations, Liquidity, and Capital Resources at
https://www.sec.gov/corpfin/covid-19-disclosure-considerations
Prabu Natarajan
Science Applications International Corporation
January 4, 2021
Page 2
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 Kathryn Jacobson, Senior Staff Accountant at (202) 551-
3365 or Robert Littlepage, Accountant Branch Chief at (202) 551-3361 if you
have questions
regarding comments on the financial statements and related matters. Please
contact Edwin Kim,
Attorney-Advisor 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
January 4, 2021 Page 2 Office of Technology
FirstName LastName