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United States securities and exchange commission logo





                             April 4, 2024

       Ronald L.G. Tsoumas
       Chief Financial Officer
       Methode Electronics, Inc.
       8750 West Bryn Mawr Avenue
       Suite 1000
       Chicago, Illinois 60631

                                                        Re: Methode
Electronics, Inc.
                                                            Form 10-K for the
fiscal year ended April 29, 2023
                                                            Form 10-Q for the
Quarter Ended January 27, 2024
                                                            File No. 001-33731

       Dear Ronald L.G. Tsoumas:

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

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-Q for the Quarter Ended January 27, 2024

       Notes to the Financial Statements
       Note 3. Acquisition and Disposition, page 11

   1.                                                   We note from your
disclosure that in the three months ended January 27, 2024, you
                                                        finalized the purchase
price allocation of the Nordic Lights acquisition and $77.3 million
                                                        was allocated to the
customer relationships intangible asset with a weighted average
                                                        useful life of 20
years. We also note from your disclosure on page F-12 of your Form 10K
                                                        for the fiscal year
ended April 29, 2023, that you use the straight line method to amortize
                                                        this intangible asset.
Please explain to us how you estimated or determined the estimated
                                                        useful life for this
intangible asset. We note in many instances, customer relationships
                                                        may dissipate at a more
rapid rate in the earlier periods following a company's succession
                                                        to these relationships,
with the rate of attrition declining over time until relatively few
                                                        customers or contracts
remain who persist for an extended period. Under this pattern, a
                                                        significant amount of
cash flows derived from the acquired customer base may be
 Ronald L.G. Tsoumas
Methode Electronics, Inc.
April 4, 2024
Page 2
         recognized in earlier periods and then fall to a materially reduced
level in later years. In
         this regard, please tell us what consideration was given to using an
accelerated method of
         amortization for purposes of amortizing your customer relationship
intangibles to expense,
         as it appears that this may result in a more systematic allocation of
the intangibles cost to
         the periods benefited. Refer to ASC 350-30-35-3 and 35-6.
Form 10-K for the fiscal year ended April 29, 2023

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of operations
Interface
Net Sales, page 23

2.       We note that in your discussion of the results of operations, you
discuss the amount of
         customer cost recoveries affecting net sales on both a consolidated
and segment basis.
         Please tell us, and revise to disclose, the nature of these customer
cost recoveries and how
         you are accounting for them as part of your revenue recognition.
Critical Accounting Policies and Estimates , page 26

3.       In future filings, please enhance your disclosures to provide
qualitative and quantitative
         information necessary to understand the estimation uncertainty and the
impact your
         critical accounting estimates have had or are reasonably likely to
have on your financial
         condition and results of operations. In addition, discuss how much
each estimate and/or
         assumption has changed over a relevant period and the sensitivity of
reported amounts to
         the underlying methods, assumptions and estimates used. The
disclosures should
         supplement, not duplicate, the description of accounting policies or
other disclosures in
         the notes to the financial statements. Refer to Item 303(b)(3) of
Regulation S-K and SEC
         Release No. 33-8350.
       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.

       Please contact Charles Eastman at 202-551-3794 or Claire Erlanger at
202-551-3301 with
any questions.



FirstName LastNameRonald L.G. Tsoumas                          Sincerely,
Comapany NameMethode Electronics, Inc.
                                                               Division of
Corporation Finance
April 4, 2024 Page 2                                           Office of
Manufacturing
FirstName LastName
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