SEC Comment Letter for SKYWORKS SOLUTIONS, INC. (SWKS) (CIK 0000004127) (SWKS) — Sep 28, 2009
SKYWORKS SOLUTIONS, INC. (SWKS) (CIK 0000004127)
Date: Sept. 28, 2009 · CIK: 0000004127 · Accession: 0000000000-09-054170
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-05560
Referenced dates: September 3, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 Mail Stop 3030 September 16, 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 8-K Dated September 9, 2009 File No. 001-05560
Dear Mr. Palette: We have reviewed your response letter dated September 3, 2009 and we have the following additional comment. Where indicated, we think you should revise your documents in future filings in response to this comment. If you disagree, we will cons ider your explanation as to why our comment is inapplicable or a revisi on is unnecessary. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Af ter reviewing this information, we may raise additional comments. 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.
Form 8-K dated September 9, 2009
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 provi ded a reconciliation of this forward-looking non-GAAP financia l 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 appl icable, include clear di sclosure of why any
Skyworks Solutions, Inc. Mr. Donald W. Palette September 16, 2009 Page 2 forward-looking GAAP information is not accessi ble. Identify such information that is unavailable and disclose its probable significance. Refer to Regulation G.
As appropriate, please respond to this commen t within 10 business da ys or tell us when you will provide us with a response. Please furnish a cover letter that keys your response 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. 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
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
Mail Stop 3030
September 16, 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 8-K Dated September 9, 2009
File No. 001-05560
Dear Mr. Palette:
We have reviewed your response letter dated September 3, 2009 and we have the
following additional comment. Where indicated, we think you should revise your documents in
future filings in response to this comment. If you disagree, we will cons ider your explanation as
to why our comment is inapplicable or a revisi on is unnecessary. Please be as detailed as
necessary in your explanation. In our comment, we may ask you to provide us with information
so we may better understand your disclosure. Af ter reviewing this information, we may raise
additional comments.
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.
Form 8-K dated September 9, 2009
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 provi ded a reconciliation
of this forward-looking non-GAAP financia l 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 appl icable, include clear di sclosure of why any
Skyworks Solutions, Inc.
Mr. Donald W. Palette September 16, 2009 Page 2
forward-looking GAAP information is not accessi ble. Identify such information that is
unavailable and disclose its probable significance. Refer to Regulation G.
As appropriate, please respond to this commen t within 10 business da ys or tell us when
you will provide us with a response. Please furnish a cover letter that keys your response 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.
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