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corresp

September 3, 2009

BY EDGAR SUBMISSION

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE, Mail Stop 3030

Washington, DC 20549

    Attn:

    Mr. Kevin L. Vaughn, Accounting Branch Chief

    Ms. Tara Harkins, Staff Accountant

    Re:

    Skyworks Solutions, Inc.

    Form 10-K for the Fiscal Year Ended October 3, 2008

    Form 10-Q for the Fiscal Quarter Ended April 3, 2009

    Form 8-K dated July 22, 2009

    File No. 001-05560

Ladies and Gentlemen:

     Skyworks Solutions, Inc. (“Skyworks” or the “Company”), submits this letter in response to the
comments regarding the above referenced filings contained in a letter dated August 5, 2009 from
Kevin L. Vaughn of the staff (the “Staff”) of the United States Securities and Exchange Commission
(the “Commission”), to Donald W. Palette, Chief Financial Officer of Skyworks. Responses are set
forth below and are keyed to the numbering of the comments and headings used in the Staff’s letter.
For your reference, your comments are reproduced in italics and the Company’s responses are set
forth below such comment in standard type.

     The Company’s response is as follows:

Form 10-K For the Fiscal Year Ended October 3, 2008

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operation, page 30

Critical Accounting Estimates, page 40

t781.376.3000 www.skyworksinc.com 20 Sylvan Road Woburn MA 01801 USA

United States Securities And Exchange Commission

September 3, 2009

Page 2

    1.

    Revise your discussion throughout this section in future filings to provide specific
disclosure of the significant judgments and estimates made by management in connection with
the preparation of the consolidated financial statements included with the filing. For
example, we note that management determined that significant reductions in the valuation
allowance were necessary in the current period, however, we do not see any discussion
regarding the significant judgments and estimates involved in reaching this determination.

Response:

In future filings, we will revise our discussion in Management’s Discussion and Analysis of
Financial Condition and Results of Operations – Critical Accounting Estimates to provide more
specific disclosure of the significant judgments and estimates made by management in connection
with the preparation of the consolidated financial statements included with the filing. In the
Company’s next Annual Report on Form 10-K the Company plans to revise its discussion of its
Critical Accounting Policies (and plans to provide updates in its Quarterly Reports on Form 10-Q to
the extent there are any significant changes) as follows:

    1.

    Allowance for Doubtful Accounts.

     We maintain general allowances for doubtful accounts for losses that we estimate will arise
from our customers’ inability to make required payments. These reserves are determined quarterly
and require management to make estimates of the collectability of our accounts receivable by
considering factors such as historical bad debt experience, the age of the accounts receivable
balances and the impact of the current economic climate on a customer’s ability to pay. In
addition, as we become aware of any specific receivables which may be uncollectable, we perform
additional analysis and reserves are recorded if deemed necessary. Determination of such
additional specific reserves require management to make judgments and estimates pertaining to
factors such as a customer’s credit worthiness, intent and ability to pay, and overall financial
position. If the data we use to calculate the allowance for doubtful accounts does not reflect the
future ability to collect outstanding receivables, additional provisions for doubtful accounts may
be needed and our results of operations could be materially affected.

    2.

    Inventories.

     Inventories are stated at the lower of cost, determined on a first-in, first-out basis, or
market. Each quarter, we estimate and establish reserves for excess, obsolete or unmarketable
inventory. These reserves are generally equal to the historical cost basis of the excess or
obsolete inventory and once recorded are considered permanent adjustments. Calculation of the
reserves requires management to use judgment and make assumptions about forecasted demand in
relation to the inventory on hand, competitiveness of our product offerings, general market
conditions and product life cycles upon which the reserves are based. When inventory on hand
exceeds foreseeable demand (generally in excess of twelve months), reserves are established for

United States Securities And Exchange Commission

September 3, 2009

Page 3

the value of such inventory that is not expected to be sold at the time of the review. Once
established, these write-downs are considered permanent adjustments to the cost basis of the excess
inventory.

If actual demand and market conditions are less favorable than those we project, additional
inventory reserves may be required and our results of operations could be materially affected. Some
or all of the inventories that have been reserved may be retained and made available for sale,
however, they are generally scrapped over time.

    3.

    Valuation of Long Lived-Assets.

     Carrying values for long-lived assets and definite lived intangible assets, which exclude
goodwill, are reviewed for possible impairment as circumstances warrant. Factors considered
important that could result in an impairment review include significant underperformance relative
to expected, historical or projected future operating results, significant changes in the manner of
use of assets or our business strategy, significant negative industry or economic trends and a
significant decline in our stock price for a sustained period of time. In addition, impairment
reviews are conducted at the judgment of management whenever asset / asset group values are deemed
to be unrecoverable relative to future undiscounted cash flows expected to be generated by that
particular asset / asset group. The determination of recoverability is based on an estimate of
undiscounted cash flows expected to result from the use of an asset / asset group and its eventual
disposition. Such estimates require management to exercise judgment and make assumptions regarding
factors such as future revenue streams, operating expenditures, cost allocation and asset
utilization levels, all of which collectively impact future operating performance. Our estimates
of undiscounted cash flows may differ from actual cash flows due to, among other things,
technological changes, economic conditions, changes to our business model or changes in our
operating performance. If the sum of the undiscounted cash flows (excluding interest) is less than
the carrying value of an asset or asset group, we would recognize an impairment loss, measured as
the amount by which the carrying value exceeds the fair value of the asset or asset group.

    4.

    Goodwill and Intangible Assets with Indefinite Useful Lives.

     Goodwill and intangible assets with indefinite useful lives are tested at least annually for
impairment in accordance with the provisions of SFAS No. 142, Goodwill and Other Intangible Assets.
Intangible assets with indefinite useful lives comprise an insignificant portion of the total book
value of our goodwill and intangible assets. We assess the need to test our goodwill for impairment
on a regular basis. Pursuant to the guidance provided under SFAS No. 131, we have determined that
we have only one reporting unit for the purposes of allocating and testing goodwill under SFAS No.
142.

     The goodwill impairment test is a two-step process. The first step of our impairment analysis
compares our fair value to our net book value to determine if there is an indicator of

United States Securities And Exchange Commission

September 3, 2009

Page 4

impairment. To determine fair value, SFAS No. 142 allows for the use of several valuation
methodologies, although it states that quoted market prices are the best evidence of fair value and
shall be used as the basis for measuring fair value where available. In our assessment of our fair
value, we consider the average market price of our common stock surrounding the selected testing
date, the number of shares of our common stock outstanding during such period and other marketplace
activity and related control premiums. If the calculated fair value is determined to be less than
the book value of the Company, then we perform step two of the impairment analysis. Step two of
the analysis compares the implied fair value of our goodwill, to the book value of our goodwill.
If the book value of our goodwill exceeds the implied fair value of our goodwill, an impairment
loss is recognized equal to that excess. In Step 2 of our annual impairment analysis, we primarily
use the income approach methodology of valuation, which includes the discounted cash flow method as
well as other generally accepted valuation methodologies, to determine the implied fair value of
our goodwill. Significant management judgment is required in preparing the forecasts of future
operating results that are used in the discounted cash flow method of valuation. Should step two
of the impairment test be required, the estimates we would use would be consistent with the plans
and estimates that we use to manage our business. In addition to testing goodwill for impairment
on an annual basis, factors such as unexpected adverse business conditions, deterioration of the
economic climate, unanticipated technological changes, adverse changes in the competitive
environment, loss of key personnel and acts by governments and courts, are considered by management
and may signal that our intangible assets have become impaired and result in additional interim
impairment testing.

     In fiscal 2009, we performed impairment tests of our goodwill on January 3, 2009, April 4,
2009 and on July 4, 2009. The first impairment test was triggered by a significant decline in our
stock price and deterioration in the macro-economic climate during the first fiscal quarter. The
second impairment test was triggered by a restructuring action announced on January 22, 2009 and
the third test was conducted on the first day of the fourth fiscal quarter, July 4, 2009, in
accordance with our regularly scheduled annual testing. The results of all three of these tests
indicated that none of our goodwill was impaired based on Step 1 of the test; accordingly Step 2 of
the test was not performed. Any management judgments and assumptions made in these tests were
generally consistent with those made in prior periods.

    5.

    Income Taxes.

     We use the asset and liability method of accounting for income taxes. Under the asset and
liability method, deferred tax assets and liabilities are recognized for the estimated future tax
consequences attributable to differences between the financial statement carrying amounts of
existing assets and liabilities and their respective tax basis. This method also requires the
recognition of future tax benefits such as net operating loss carry forwards, to the extent that
realization of such benefits is more likely than not. Deferred tax assets and liabilities are
measured using enacted tax rates expected to apply to taxable income in the years in which those
temporary differences are expected to be recovered or settled. The effect on deferred tax assets

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September 3, 2009

Page 5

and liabilities of a change in tax rates is recognized in income in the period that includes the
enactment date.

     The carrying value of our net deferred tax assets assumes we will be able to generate
sufficient future taxable income in certain tax jurisdictions, based on estimates and assumptions.
If these estimates and related assumptions change in the future, we may be required to record
additional valuation allowances against our deferred tax assets resulting in additional income tax
expense in our consolidated statement of operations. Management evaluates the realizability of the
deferred tax assets and assesses the adequacy of the valuation allowance quarterly. Likewise, in
the event we were to determine that we would be able to realize our deferred tax assets in the
future in excess of our net recorded amount, an adjustment to the deferred tax assets would
increase income or decrease the carrying value of goodwill in the period such determination was
made.

     The determination of recording or releasing tax valuation allowances is made, in part,
pursuant to an assessment performed by management regarding the likelihood that we will generate
future taxable income against which benefits of our deferred tax assets may or may not be realized.
This assessment requires management to exercise significant judgment and make estimates with
respect to our ability to generate revenues, gross profits, operating income and taxable income in
future periods. Amongst other factors, management must make assumptions regarding overall business
and semiconductor industry conditions, operating efficiencies, our ability to develop products to
our customers’ specifications, technological change, the competitive environment and changes in
regulatory requirements which may impact our ability to generate taxable income and, in turn,
realize the value of our deferred tax assets. In addition, the current uncertain economic
environment limits our ability to confidently forecast our taxable income. In fiscal years 2008
and 2009, our estimates of future taxable income were prepared in a manner consistent with our
assessment of various factors, including market and industry conditions, operating trends, product
life cycles and competitive and regulatory environments.

     The calculation of our tax liabilities includes addressing uncertainties in the application of
complex tax regulations. FIN 48 clarifies the accounting for uncertainty in income taxes recognized
in an enterprise’s financial statements in accordance with SFAS 109. FIN 48 prescribes a
recognition threshold and measurement attribute for the financial statement recognition and
measurement of a tax position taken or expected to be taken in a tax return.

     We recognize liabilities for anticipated tax audit issues in the United States and other tax
jurisdictions based on our recognition threshold and measurement attribute of whether it is more
likely than not that the positions we have taken in tax filings will be sustained upon tax audit,
and the extent to which, additional taxes would be due. If payment of these amounts ultimately
proves to be unnecessary, the reversal of the liabilities would result in tax benefits being
recognized in the period in which it is determined the liabilities are no longer necessary. If the
estimate of tax liabilities proves to be less than the ultimate assessment, a further charge to
expense would result.

United States Securities And Exchange Commission

September 3, 2009

Page 6

- Goodwill and Intangible Assets, page 43

    2.

    Please expand your discussion of your goodwill impairment evaluation here in future filings
to address the following:

    •

    Disclose the number of reporting units that you have identified.

    •

    Disclose the specific results of your current period impairment evaluation,
including a discussion of whether any of your reporting units failed step 1 of the
impairment test.

    •

    To the extent you are required to perform step 2 of the impairment test for any of
your reporting units, disclose the specific methodologies used to determine the implied
fair value of the goodwill.

    •

    Disclose any significant assumptions or judgments made in connection with your
current period impairment testing. Discuss how the current period as