September 26, 2018

Manavendra S. Sial
Chief Financial Officer
SunPower Corporation
77 Rio Robles
San Jose, California 95134

       Re: SunPower Corporation
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 15, 2018
           Form 10-Q for the Quarterly Period Ended July 1, 2018
           Filed August 1, 2018
           File No. 001-34166

Dear Mr. Sial:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-K for the Fiscal Year Ended December 31, 2017

Item 8. Financial Statements
Note 6. Leases, page 124

1.    We note the significance of the $624.3 million impairment charge to the
pre-impairment
      carrying amounts of your residential lease assets. In light of the
magnitude of the charge,
      please explain to us how the two courses of action described in your
disclosure were
      considered in your estimates of future cash flows. Also, describe to us
the business,
      economic or other factors you believe are responsible for the significant
difference
      between the carrying amounts and estimated fair values of the assets as
of December 31,
      2017.
 Manavendra S. Sial
FirstName Corporation
SunPower LastNameManavendra S. Sial
Comapany 26, 2018
September NameSunPower Corporation
September 26, 2018 Page 2
Page 2
FirstName LastName
2.       We also note that you recognized additional impairment charges related
to residential
         leasing assets in the first and second quarters of 2018. Please
clarify for us the reasons for
         the additional impairment charges, including the extent to which those
charges relate to
         assets held as of December 31, 2017. In light of disclosure in the
Form 10-K and Form
         10-Q for the quarter ended April 1, 2018 that you are pursuing sale of
the residential
         leasing portfolio, explain to us how that decision is considered in
the accounting model
         you applied for new lease contracts.
3.       As a related matter, we note in the Form 10-Q for the quarter ended
July 1, 2018, you now
         disclose that you may either sell or refinance the residential lease
portfolio. The
         disclosure that you may refinance the portfolio appears to be new to
the second quarter.
         Please respond to the following:

             Reconcile for us the prior disclosure that you were pursuing sale
of the residential
             lease portfolio with the current disclosure that you may either
sell or refinance the
             portfolio.
             In light of the revised disclosure in the second quarter, explain
to us why you believe
             the plan described in your filings was sufficiently robust to
support recognition of the
             impairment charges recorded in your financial statements. Explain
the basis in GAAP
             for your conclusion.
             Explain how the change to your plan that may now include
refinancing rather than sale
             of the portfolio is considered in your accounting for the leases.
4.       Please tell us the accounting model/models you used in evaluating and
measuring
         the impairment charges. Cite the accounting literature upon which you
relied.
Form 10-Q for the Quarterly Period Ended July 1, 2018

Summary of Significant Accounting Policies
Revenue Recognition, page 9

5.       We note your disclosure on page 10 that you view the sale of tax
credits as a distinct
         performance obligation. Please provide us with background information
on the tax
         credits, and explain to us your basis for accounting for the sale of
tax credits as a
         performance obligation within the scope of ASC 606.
       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.
 Manavendra S. Sial
SunPower Corporation
September 26, 2018
Page 3

       You may contact Eric Atallah at (202) 551-3663 or Gary Todd, Senior
Accountant, at
(202) 551-3605 with any questions.



FirstName LastNameManavendra S. Sial                     Sincerely,
Comapany NameSunPower Corporation
                                                         Division of
Corporation Finance
September 26, 2018 Page 3                                Office of Electronics
and Machinery
FirstName LastName