SecProbe.io

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Mail Stop 6010

      February 24, 2006

Via Facsimile and U.S. Mail

Mr. David J. Aldrich
Chief Executive Officer
Skyworks Solutions, Inc.
20 Sylvan Road
Woburn, MA   01801

	Re:	Skyworks Solutions, Inc.
		Form 10-K for the year ended September 30, 2005
Filed December 14, 2005
Form 10-Q as of December 31, 2005
		File No. 1-05560

Dear Mr. Aldrich:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
future
filings in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the fiscal year ended September 30, 2005

Cover Page

1. Please revise all of your future Forms 10-K and Forms 10-Q to
clearly indicate the actual date of the end of the period for
which
you are reporting and not as of the last day of the calendar
month.
Your current presentation may be confusing to investors.

Note 2. Summary of Significant Accounting Policies, page 43

Fiscal Year, page 43

2. Since your fiscal year ends on the Friday closest to September
30th, please revise future filings to present your consolidated
financial statements as of that date and for the fiscal periods
ended
at that date instead as of the last day of the calendar month for
convenience.  Your current presentation may be confusing to
investors.  This comment also applies to the disclosure in Form
10-Q.

Form 10-Q for the quarter ended December 30, 2005

Consolidated Statements of Operations

3. Please revise all future filings to remove the footnote
included
on the face of the statement.  Net income including pro forma
stock-
based compensation expense for the first quarter of fiscal 2005,
representing what net income would have been considering the
effect
of accounting for share-based payment transactions in accordance
with
SFAS 123(R), is a non-GAAP financial measure.  According to Item
10(e) of Regulation S-K, you may not present non-GAAP financial
measures on the face of your financial statements prepared in
accordance with GAAP.  You should continue to present the pro
forma
disclosures required by SFAS 123(R) in the notes to your financial
statements.

Note 2. Summary of Significant Accounting Policies

Deferred Financing Costs, page 7

4. Please revise all future filings to amortize financing costs
using
the effective interest method instead of on a straight-line basis
over the life of the financing.  Refer to paragraph 16 of APB 21.

Management`s Discussion and Analysis

5. Please expand the discussion in this section in future filings
to
highlight the effects of differences between the accounting for
share-based payment arrangements before and after the adoption of
Statement 123(R) and changes to share-based payment arrangements.
In
addition, include material qualitative and quantitative
information
about any of the items outlined in SAB Topic 14-M, as well as
other
information that could affect comparability of financial
statements
from period to period.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities and
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* The company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* 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.
      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact David Burton, Staff Accountant, at (202)
551-
3626, Michele Golhke, Branch Chief, at (202) 551-3327 or me at
(202)
551-3671 if you have questions regarding these comments.

							Sincerely,

      Martin James
					  		Senior Assistant Chief
Accountant
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Mr. David J. Aldrich
Skyworks Solutions, Inc.
February 24, 2006
Page 3

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