SecProbe.io

January 30, 2013

Via E -mail
Mr. David J. Aldrich
Chief Executive Officer, President and Director
Skyworks Solutions, Inc.
20 Sylvan Road
Woburn, Massachusetts  01801

 Re: Skyworks Solutions, Inc.
  Form 10-K for the Fiscal Year Ended  Septe mber 28, 201 2
Filed  November 21, 2012
  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 do not intend to expand our
review to other portions of your documents.   In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have  additional comments.

Form 10 -K for the Fiscal Year Ended September 28, 2012

Item 8.  Financial Statements and Supplementary Data

Note 2.  Summary of Significant Acc ounting Policies

Cash and Cash Equivalents, page 42

1. You disclose that your cash equivalents have a weighted average maturity of 90 days or
less.  Please tell us how the company considered the definition of cash equivalents in
FASB ASC 230 -10-20 in your a ccounting policy.  We note that g enerally, only
investments with original maturities of three months or less qualify under the definition.

Mr. David J. Aldrich
Skyworks Solutions, Inc.
January 30, 2013
Page 2

 Inventory, page 42

2. On page 42, you refer to inventory reserves for excess, obsolete and unmarketable
inventory an d state that reserves are generally equal to historical cost.  Please explain
how the company considers FASB ASC 330 -10-35-1 and 35 -2 in determining whether
there is evidence that the utility of goods, in their disposal in the ordinary course of
business, will be less than cost, including due to changes in price levels .

3. Further, on page 31, you disclose that you value inventory at the lower of cost or fair
market value.  Please discuss how the company determines fair market value and applies
FASB ASC 330 -10-35 and the definition of market value. Refer to FASB ASC 330 -10-
20.

Goodwill and Indefinite Intangible Assets, page 43

4. Your disclosure in footnote 18 on page 62 indicates business units are aggregated into
one reporting segment based on similar econo mic characteristics.  Your disclosure here
indicates you have one reporting unit for purposes of allocating and testing goodwill.
Please explain how you applied FASB ASC 350 -20-35-33 through 35 -38 in determining
your reporting unit.

Note 18.   Segment Information and Concentrations, page 62

5. Please tell us about the company’s analysis in determining that it has one reportable
segment under ASC 280 -10-50.  Your response should address the following:

 Please tell us the title(s) of your chief op erating decision maker(s).
 Please provide us with a representative sample for fiscal 2012 of the contents of
the operating results that are r egularly reviewed by your chief operating decision
maker to make decisions about resources to be allocated and asse ss performance.
Refer to FASB ASC 280 -10-50-1.
 Explain whether any operating segments were aggregated under ASC 280 -10-50-
11 and if so, why, providing a quantitative and qualitative analysis.
 Summarize the type of information you provide to your CODM about your front -
end solutions group and high -performance analog group and how the CODM uses
the information.
 Discuss the extent to which the compensation of your executive vice presidents
and general managers are based upon business unit performance.

6. Please tell us about your consideration of the disclosures required by FASB ASC 280 -10-
50-40.

Mr. David J. Aldrich
Skyworks Solutions, Inc.
January 30, 2013
Page 3

  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 the information the Securities Exchange Act of
1934 and  all applicable Exchange Act rules require .  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 th ey have made.

 In responding to our comments, please provide  a written 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 securiti es laws of the United States.

You may contact Gary Newberry, Staff Accountant, at (202) 551 -3761 or Kate Tillan ,
Assistant Chief  Accountant, at (202) 551 -3604 if you have questions regarding these comments.
In this regard, do not hesitate to contact me at (202) 551 -3671.

        Sincerely,

        /s/ Kate Tillan for

        Martin James
        Senior Assistant Chief Accountant