SecProbe.io

April  3, 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 March 29 , 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 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 18. Segment Information and Concentrations, page 62

1. We note from your response to prior comment 1, that t he Chief Financial Officer reviews the
business unit non -GAAP profit and loss statements in order to understand and assess the f inancial
performance of the business unit s and compare that with corporate level targets established by the
CODM.  Please respond to the following:

 Summarize the contents of the business unit non -GAAP profit and loss statements and
tell us how often the statements  are prepared.  Also discuss whether you prepare forecasts
for these units.

Mr. David J. Aldrich
Skyworks Solutions, Inc.
April 3 , 2013
Page 2

  Tell us in more detail how you use the business unit non -GAAP profit and loss
statements.  For example, since you state that gross profit is measured at the factory or
Company leve l without regard to business unit performance , explain why you prepare
non-GAAP profit and loss statements for the business units and how the individual line
items are utilized by the company.
 Provide us with an organization chart that includes your busine ss unit executive vice
presidents.
 Provide a summary job description of the business unit executive vice presidents and
explain how the functional and business units interact with each other.
 Explain how the CEO is able to evaluate the performance of the business unit executive
vice presidents and compensate them based on the business units if the CEO is not
provided and does not use the business unit level financial information.  Tell us who
makes the decision regarding their incentive compensation and th e basis for the
determination.
 Tell us why you do not also consider the CFO a member of the CODM.  Refer to FASB
ASC 280 -10-50-5 through 50 -9.

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

        Sincerely,

        /s/ Kate Tillan for

        Martin James
        Senior Assistant Chief Accountant