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March 3, 2006

BY ELECTRONIC SUBMISSION

United States Securities and Exchange Commission

Division of Corporate Finance

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Martin James

    RE:

    Skyworks Solutions, Inc.

Form 10-K for the fiscal year ended September 30, 2005

Form 10-Q as of December 30, 2005

File No. 1-05560

Ladies and Gentlemen:

     This letter is being furnished in response to comments contained in the letter dated February
24, 2006 (the “Letter”) from Martin James of the Staff (the “Staff”) of the Securities and
Exchange Commission (the “SEC”) to David J. Aldrich, President, Chief Executive Officer and
Director of Skyworks Solutions, Inc. (“Skyworks” or the “Company”). The comments
and responses are set forth below and are keyed to the sequential numbering of the comments and the
headings used in the Letter.

Form 10-K for the fiscal year ended September 30, 2005

Cover Page

Comment:

    1.

    Please revise all of your future Forms 10-K and Forms 10-Q to clearly indicate
the actual date of
the end of the period for which you are reporting and not as of the last day of the
calendar month. Your current presentation may be confusing to investors.

Response:

    In future Forms 10-K and Forms 10-Q filings, the Company will clearly indicate the actual date of the end of the reporting period on the cover page.

Note 2. Summary of Significant Accounting Policies, Fiscal Year, Page 43

Comment:

    2.

    Since your fiscal year ends on the Friday closest to September 30th,
please revise future filings to
present your consolidated financial statements as of that date and for the fiscal
periods ended at that date instead as of the last day of the calendar month for
convenience. Your current presentation may be confusing to investors. This comment
also applies to the disclosure in the Form 10-Q.

Response:

    In future filings, including Forms 10-K and Forms 10-Q, the Company will present its
consolidated
financial statements as of the actual date and for the fiscal periods ended at that date.

Form 10-Q for the quarter ended December 30, 2005

Consolidated Statement of Operations

Comment:

    3.

    Please revise all future filings to remove the footnote included on the face of
the statement. Net
income including pro forma stock-based compensation expense for the first quarter of
fiscal 2005, representing what net income would have been considering the effect of
accounting for share-based payment transactions in accordance with SFAS 123(R), is a
non-GAAP financial measure. According to Item 10(e) of Regulation S-K, you may not
present non-GAAP financial measures on the face of your financial statements prepared
in accordance with GAAP. You should continue to present the pro forma disclosures
required by SFAS 123(R) in the notes to your financial statements.

Response:

    In future filings the Company will remove the footnote included on the face of the
Consolidated
Statement of Operations. Additionally, the Company will continue to present the pro forma disclosures required by SFAS 123(R) in the notes to our financial statements.

Note 2. Summary of Significant Accounting Policies

Deferred Financing Costs, Page 7

Comment:

    4.

    Please revise all future filings to amortize financing costs using the
effective interest method
instead of on a straight-line basis over the life of the financing. Refer to
paragraph 16 of APB 21.

Response:

    In the future the Company will calculate the amortization of financing costs using the
effective
interest method as well as on a straight-line basis. Pursuant to paragraph 15 of APB 21, the
Company will report amortization utilizing the straight-line method unless it is materially
different
than the amortization as calculated using the effective interest method. If the amount of
amortization is materially different under the effective interest method, then the amount as
calculated under this methodology will be recorded and reported.

    The Company supplementally advises the Staff that since no principal payments are due until
the entire debt instrument becomes due in November 2007, the effective interest method
and the straight-line method will effectively yield the same amortization over that
period.

Management’s Discussion and Analysis

Comment:

    5.

    Please expand the discussion in this section in future filings to highlight the
effects of differences
between the accounting for share-based payment arrangements before and after the
adoption of Statement 123(R) and changes to share-based payment arrangements. In
addition, include material qualitative and quantitative information about any of the
items outlined in SAB Topic 14-M, as well as other information that could affect
comparability of financial statements from period to period.

Response:

    As stated in SEC Release FR-72, the principal objectives of MD&A are to give our
readers a view of the Company through the eyes of management, to provide the context
within which financial information should be analyzed and to provide information
about the quality of, and potential variability of, our company’s earnings and cash
flow, so that investors can ascertain the likelihood that past performance is
indicative of future performance. Since the adoption of Statement 123(R) resulted in
significant differences between the financial statements of the periods before and
after the adoption, the Company will both enhance and expand its discussion of these
differences in the MD&A. Furthermore, the Company will consider in future filings
material qualitative and quantitative information about any of the following, as well
as other information that might affect comparability of financial statements from
period to period, and disclose such information in the MD&A as well as the footnotes
to the financial statements:

    •

    Transition method selected (e.g., modified prospective application or modified
retrospective application) and the resulting financial statement impact in current
and future reporting periods;

    •

    Method utilized by the company to account for share-based payment arrangements in
periods prior to the adoption of Statement 123R and the impact, or lack thereof, on
the prior period financial statements;

    •

    Modifications made to outstanding share options prior to the adoption of Statement
123R and the reason(s) for the modification;

    •

    Differences in valuation methodologies or assumptions compared to those that were
used in estimating the fair value of share options under Statement 123;

    •

    Changes in the quantity or type of instruments used in share-based payment
programs, such as a shift from share options to restricted shares;

    •

    Changes in the terms of share-based payment arrangements, such as the addition of
performance conditions; and

    •

    Total compensation cost related to nonvested awards not yet recognized and the
weighted average period over which it is expected to be recognized.

    The Company did provide the aforementioned disclosures in the footnotes to the
consolidated financial statements and in future filings will provide these
disclosures in the MD&A as well.

     Please feel free to contact me at (781) 376-3099 should you require additional information or
have any questions concerning this letter.

    Very truly yours,

    /s/ Mark  V.B. Tremallo

    Mark  V.B. Tremallo, Esq.

    Vice President, General Counsel

    cc:

    David J. Aldrich, President and Chief Executive Officer

Allan M. Kline, Vice President, Chief Financial Officer

Paul E. Vincent, Vice President, Finance