SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

   Mail Stop 3030

August 5, 2009
Via Facsimile and U.S. Mail

 Mr. Donald W. Palette Chief Financial Officer Skyworks Solutions, Inc. 20 Sylvan Road Woburn, Massachusetts  01801
 Re: Skyworks Solutions, Inc.
Form 10-K for the Fiscal Year Ended October 3, 2008
 Filed December 2, 2008 Form 10-Q for the Quarter Ended April 3, 2009 Form 8-K Dated July 22, 2009 File No.  001-05560

Dear Mr. Palette:
We have reviewed your filing and have the following comments.  We have limited our
review to only your financial st atements and related disclosures and will make no further review
of your documents.  Where indicated, we think yo u should revise your documents in response to
these comments.  If you disagree, we will consid er your explanation as to why our comments are
inapplicable or a revision is unnecessary.  Please be as detailed as necess ary in your explanation.
In some of our comments, we may ask you to pr ovide us with information so we may better
understand your disclosure.  After reviewing th is 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 ove rall disclosure in your filing.
We look forward to working with you in thes e respects.  We welcome any questions you may
have about our comments or any other aspect of our review.  Feel free to  call us at the telephone
numbers listed at the end of this letter.

Skyworks Solutions, Inc.
Mr. Donald W. Palette
August 5, 2009 Page 2  Form 10-K For the Fiscal Year Ended April 3, 2009

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operation,
page 30

Critical Accounting Estimates, page 40

1. Revise your discussion throughout this section in future filings to provide specific
disclosure of the significant judgments and estimates made by management in connection
with the preparation of the consolidated fina ncial statements included with the filing. For
example, we note that management determined that significant reductions in the valuation
allowance were necessary in the current pe riod, however, we do not see any discussion
regarding the significant judgments a nd estimates involved in reaching this
determination.

- Goodwill and Intangible Assets, page 43

2. Please expand your discussion of your goodwill im pairment evaluation here in future
filings to address the following:

• Disclose the number of reporting units that you have identified.

• Disclose the specific results of your current period impairment evaluation, including a
discussion of whether any of your reporting un its failed step 1 of the impairment test.

• To the extent you are required to perform step 2 of the impairment test for any of your reporting units, disclose the specific methodologies used to determine the implied fair value of the goodwill.

• Disclose any significant assumptions or judgments made in connection with your current period impairment testing. Discuss how the current period assumptions and judgments
compare with those made in prior periods, including disclosure of the reason for and
impact of any significant changes.

Item 8. Financial Statements and Supplementary Data, page 47

-Consolidated Statement of Operations, page 49

3. Please revise your future filings to remove the total captions and amounts from the stock-based compensation table included on the face of your consolidated statements of
operations. Otherwise, as indi cated in SAB Topic 14-F, plea se revise the statement to
present the related stock-based compensation charges in a parenthetical note to the
appropriate income statement caption. That gui dance also indicates that you may present
the information in the notes to the financial statements or within MD&A.

Skyworks Solutions, Inc.
Mr. Donald W. Palette
August 5, 2009 Page 3  Note 5. Inventory, page 60

4. We note your disclosure on pages 12 and 53 th at you ship products on consignment to
certain customers. Please revise this note in  future filings to separately present your
consigned inventory. Refer to Question 2 of SAB Topic 13(A)(2).

Form 10-Q for the Quarter Ended April 3, 2009
 Note 11. Restructuring and Other Charges

5. We note your disclosures here and MD&A rela ted to your restructuring plan that was
announced on January 22, 2009. Please revise your MD&A in future filings to include the
disclosures detailed in SAB Topic 5.P.4, includi ng disclosure of the expected effects on
future earnings and cash flows resulting from the plan.

Form 8-K dated July 22, 2009

6. We note your presentation of various non-GAAP financial measures throughout this
Form 8-K and the narrative discussion regarding the use of the non-GAAP financial measures included following the discussion of the various reconciling items. However, the narrative discussion appears vague as it  does not appear to clearly describe the
usefulness of each non-GAAP financial measure you have presented. Please revise future
filings to provide separate  disclosures regarding the usefulness of each non-GAAP
financial measure presented. In this regard, please also revise the discussion of each non-
GAAP financial measure to explain why you believe each of the items being excluded is not indicative of your ongoing operations. Refe r to Regulation G and FAQ 8 Regarding
the Use of Non-GAAP Financial Measures dated June 13, 2003.

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 that keys your responses to our comment and provides any requested information.  Detailed cover letters greatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
responses to our comments.    We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure
in the filing to be certain that the filing includes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.

Skyworks Solutions, Inc.
Mr. Donald W. Palette  August 5, 2009 Page 4
   In connection with responding to our comme nts, please provide, in writing, a statement
from the company acknowledging that:  ‚ the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
‚ staff comments or changes to disclosure in re sponse 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 advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
 You may contact Tara Harkins, Staff Accountant, at (202) 551-3639 or me at (202) 551-
3643 if you have questions regarding these comments.  In this regard, do no t hesitate to contact
Martin James, Senior Assistant Chief Accountant, at (202) 551-3671.

       S i n c e r e l y ,

        Kevin L. Vaughn         A c c o u n t i n g  B r a n c h  C h i e f