January 24, 2020

Daniel J. Durn
Chief Financial Offier
3050 Bowers Avenue
P.O. Box 58039
Santa Clara, CA 95052

           Form 10-K for the fiscal year ended October 27, 2019
           File No. 000-06920

Dear Mr. Durn:

       We have reviewed your filing and have the following comments. In some of
comments, we may ask you to provide us with information so we may better
understand your

       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

       After reviewing your response to these comments, we may have additional

Form 10-K for the fiscal year ended October 27, 2019

Financial Statements
Consolidated Statements of Operations, page 61

1.    Based on your disclosures under Business, including the discussion of
your reportable
      segments, please explain to us your consideration of the disclosure
requirements of Rule
      5-03(b)(1)(d) and Rule 5-03(b)(2)(d) of Regulation S-X.
Note 1 Summary of Significant Accounting Policies, page 66

2.    In regard to your adoption of ASC 606, please address the following:
        We note your disclosure under identifying the performance obligations
that service
           agreements are one performance obligation. Please more fully explain
the nature of
           the products and services transferred in these agreements and
provide us your
           analysis regarding how you determined that the products and services
in these
           agreements should be combined. Refer to ASC 606-10-25-19 through 22.
 Daniel J. Durn
January 24, 2020
Page 2
              We note your disclosures under payment terms that "terms vary by
              "generally, the majority of payments are due within a certain
number of days from
              shipment of goods or performance of service", and "the remainder
is typically due
              upon customer technical acceptance". Based on your other
disclosures, it is not clear
              if or how customer acceptance provisions impact when you
recognize revenue.
              Please explain the nature of these customer acceptance provisions
and how you
              considered if and how they affect your determination of when your
customer obtains
              control of products or services. Refer to ASC 606-10-25-30(e) and
ASC 606-10-55-
              86 and 55-87.
              Please explain your consideration of providing disaggregated
disclosures for revenue
              recognized at a point in time and over time based on the
provisions of ASC 606-10-
              50-5 and ASC 606-10-55-89 through 55-91.

        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 SiSi Cheng at 202-551-5004 or Anne Mcconnell at
202-551-3709 if
you have any questions.

FirstName LastNameDaniel J. Durn                              Sincerely,
                                                              Division of
Corporation Finance
January 24, 2020 Page 2                                       Office of
FirstName LastName