SecProbe.io

March 15, 2013

Via E -mail
Mr. David J. Aldrich
Chief Ex ecutive 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 September 28, 2012
Filed November 21, 2012
  File No.   1-05560

Dear Mr . Aldrich:

We have reviewed your response letter  dated February 28, 2013 and filing and have the
following comments.   In some of our comments, we may ask you to provide us with information
so we may be tter 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 c ircumstances, 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 Supp lementary Data

Note 18. Segment Information and Concentrations, page 62

1. Further to your response to prior comment 5, please respond to the following:

 Discuss how you determined that your CODM is the President and Chief Executive
Officer (“CEO”).  Refer to FASB ASC 280 -10-50-5 through 50 -9.
 Discuss whether your Executive Vice Presidents and General Managers of the High
Performance Analog business unit and Front End Solutions business unit are directly
accountable to and maintain regular contact with someone within your organization

Mr. David J. Aldrich
Skyworks Solutions, Inc.
March 15, 2013
Page 2

 (such as your CEO) to discuss operating activities, financial results, forecasts, or
plans for each business unit.
 We note that you prepare your internal financial reports monthly .  Please explain the
differences, if any, b etween the sample quarterly report provided with your response
and the monthly reports.
 Tell us why your response states that you primarily  provide information to the
CODM on a consolidated basis .  Discuss the nature of any other financial information
provided to the CODM by business units.
 We note that you prepare non-GAAP profit and loss statements for each business
unit.  Please tell us who receives these financial statements above the level of the
business unit managers and summarize how the information  is used.

2. Further to your response to prior comment 6, please tell us in detail why you consider all
of your products to be similar, expanding on each of the factors you noted in your
response – i.e.,  common customers, production processes, sales and distribution
channels, end market applications and underlying technology.

3. Explain to us why, on your fourth quarter 2012 earnings call, you discussed revenues
grouped into (i) high -performance analog products and (ii) handsets and smartphones
products.  T ell us why you believed this presentation was meaningful or significant to the
analysts and other participants on that call.

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