Attn: | Mr. Kevin L. Vaughn, Accounting Branch Chief Ms. Tara Harkins, Staff Accountant |
Re: | Skyworks Solutions, Inc. Form 8-K Dated September 9, 2009 File No. 001-05560 |
1. | We note that you have provided a forward-looking non-GAAP financial measure of non-GAAP diluted EPS. However, we do not see where you have provided a reconciliation of this forward-looking non-GAAP financial measure with the corresponding forward-looking GAAP financial measure as required by Regulation G or otherwise provided the disclosures required by Regulation G for forward-looking non-GAAP financial measures. Please revise future filings to comply by providing reconciling information that is available without unreasonable effort. As applicable, include clear disclosure of why any |
forward-looking GAAP information is not accessible. Identify such information that is unavailable and disclose its probable significance. Refer to Regulation G. | ||
2. | Response: With respect to all future disclosures of material information containing a forward-looking non-GAAP financial measure, the Company will provide reconciling information to the most directly comparable GAAP financial measure to the extent that it is available without unreasonable effort, as well as any other information required by Regulation G. |
| the Company is responsible for the adequacy and accuracy of the disclosure in its filings; | ||
| Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and | ||
| the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Very truly yours, |
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/s/ Donald W. Palette | ||||
Donald W. Palette | ||||
Chief Financial Officer |
cc: | Wilmer Cutler Pickering Hale and Dorr LLP David E. Redlick, Esq. Peter N. Handrinos, Esq. |