SecProbe.io

April  25, 2013

Via E -mail
Mr. David J. Aldrich
Chief Ex ecutive Officer  and President
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.   1-5560

Dear Mr . Aldrich:

We have reviewed your response letter  dated April 17, 2013 and filings and have the
following comment s.  In some of our comments, we may ask you to provide us with information
so we may better unde rstand 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 comment s apply to your facts and circumstan ces, please tell us why in your response.

After reviewing the information you provide in response to th ese comment s, 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. In your response, you told us that on November 20, 2012, the company consolidated its
FES and HPA business units under an Executive Vice President and C orporate General
Manager.  Further, you responded that your single business unit is now composed of
eight product lines, each (i) led by a product line Vice President (who reports directly to
the Executive VP and Corporate General Manager); (ii) with its o wn product
development and marketing initiatives; and (iii) with its own product line profit and loss
estimate (“Product Line P&L”).

Mr. David J. Aldrich
Skyworks Solutions, Inc.
April 25, 2013
Page 2

  Please describe to us each of your eight product lines, including the basis on
which you have grouped your products.
 Tell us whether these product lines represent business units or operating segments
and whether, as disclosed on page 62 of your Form 10 -K, these business units also
share similar economic characteristics, long term business models, research and
development expenses and selling, general and administrative expenses.
 Tell us whether any operating segments were aggregated into your one reportable
segment pursuant to ASC 280 -10-50-11 and if so, provide a quantitative and
qualitative analysis that supports your conclusion that aggregation was
appropriate.

2. Given the significant changes noted in your response, and to help us understand the
company’s analysis in determining that it continues to have one reportable segment under
ASC 280 -10-50, please address the fol lowing:

 Discuss whether your product line vice presidents are directly accountable to and
maintain regular contact with someone within your organization to discuss
operating activities, financial results, forecasts, or plans for each product line.
 Tell us  why you do not also consider the Executive VP and Corporate General
Manager  a member of the CODM.  Refer to FASB ASC 280 -10-50-5 through 50 -
9.  Please be sufficiently detailed in your response.
 Provide us with a representative sample for fiscal 2013 of th e 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 assess performance.
Refer to FASB ASC 280 -10-50-1.
 Provide us with a sample of the 2013 Product Li ne P&L package used by the
Executive VP and Corporate General Manager.
 Summarize the type of information you provide to your CODM about your eight
product lines.

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 th ese comment s.
In this regard, do not hesitate to contact me at (202) 551 -3671.

        Sincerely,

        /s/ Kate Tillan for

        Martin James
        Senior Assistant Chief Accountant