July 12, 2019

Clay Griggs
VIce President, Corporate Controller
LOWES COMPANIES INC
1000 Lowe's Blvd, NB4551
Mooresville, NC 28117

       Re: LOWES COMPANIES INC
           Form 10-K for Fiscal Year Ended February 1, 2019
           Filed April 2, 2019
           File No. 001-07898

Dear Mr. Griggs:

       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 Fiscal Year Ended February 1, 2019

Non-GAAP Financial Measures
Return on Invested Capital, page 25

1.    We note you determine Return on Invested Capital using a non-GAAP
financial measure,
      net operating profit after tax (NOPAT). However, we note you do not
present this ratio
      using the most directly comparable GAAP measure. Please ensure all
non-GAAP
      financial measures you present in future filings, including earnings
releases filed under
      Form 8-K, fully comply with Item 10(e) of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Financial Condition, Liquidity and Capital Resources
Cash Flows Provided by Operating Activities, page 31

2.    We note your disclosure which states your net cash provided by operating
activities for
      2018 when compared to 2017 was driven primarily by changes in working
capital. Please
 Clay Griggs
LOWES COMPANIES INC
July 12, 2019
Page 2
         expand your disclosure to provide a more robust and insightful
explanation of the key
         drivers of your working capital changes and any other factors that
impacted your
         operating cash flows. We note significant increases in both the
carrying value of your
         inventory as well as accounts payable, but it is unclear what drove
the increases which are
         not entirely offsetting. We further note you experienced inventory
shortages and made
         efforts to remove inventory clutter and reduced lower-performing
inventory, while also
         increasing your overall level of inventory reflected on your balance
sheet. Refer to
         Section IV. B. of SEC Interpretive Release 33-8350.



Financial Statements
Cost of Sales and Selling, General and Administrative Expenses, page 52

3.       We note your disclosure regarding the primary costs classified as Cost
of Sales. We also
         note elsewhere your recent change in accounting principle, which
appears to have shifted
         certain depreciation expense to Cost of Sales. Please clarify for us
and in your
         accounting policy disclosure, the extent to which you include
depreciation expense in Cost
         of Sales. We further note you separately present depreciation below
your measure of
         gross margin. Please clarify in your document whether the depreciation
presented
         separately relates to costs of selling or otherwise explain to us your
depreciation
         presentation.



       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 Kevin Stertzel at (202) 551-3723 or John Cash at (202)
551-3768 with
any questions.



                                                              Sincerely,
FirstName LastNameClay Griggs
                                                              Division of
Corporation Finance
Comapany NameLOWES COMPANIES INC
                                                              Office of
Manufacturing and
July 12, 2019 Page 2                                          Construction
FirstName LastName