SecProbe.io

February 28, 2020
Lester Wong
Chief Financial Officer
Kulicke & Soffa Industries, Inc.
23A Serangoon North Avenue 5 #01-01
Singapore 554369
Re:Kulicke and Soffa Industries, Inc.
Form 10-K for the Fiscal Year Ended September 28, 2019
Filed November 15, 2019
File No. 000-00121
Dear Mr. Wong:
            We have reviewed your 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended September 28, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 24
1.We note that your results of operations section in MD&A discusses the changes in
revenue and gross profit by segment.  However, we note from your disclosure in Note 14
that segment operating income is the measure used by your chief operating decision maker
in deciding how to allocate resources and assess performance.  We also note that although
the Capital Equipment segment generated the larger revenue and gross profit amounts of
the two segments in fiscal 2019, it generated a loss from operations, while APS had
income from operations.  In light of this disproportionate contribution of the Capital
Equipment segment to operating income relative to its contribution to revenue, it
appears that investors would benefit from a discussion of segment operating income in
your results of operations discussion within MD&A.  Please consider revising as
appropriate.

 FirstName LastNameLester Wong
 Comapany NameKulicke & Soffa Industries, Inc.
 February 28, 2020 Page 2
 FirstName LastNameLester Wong
Kulicke & Soffa Industries, Inc.
February 28, 2020
Page 2

Notes to Consolidated Financial Statements
Note 3: Goodwill and Intangible Assets
Goodwill, page 47
2.We note your disclosure that you performed your annual assessment in the fourth quarter
of fiscal 2019 and concluded that no impairment charge was required and that during
fiscal year 2019 and through the three months ended December 28, 2019, you reviewed
qualitative factors and determined that no triggering event had occurred to indicate that
the fair value of the reporting unit is below its carrying value.  We further note that net
revenues for your capital equipment segment in fiscal 2019 decreased 46.2% from fiscal
2018 and decreased 11.7% for the three months ended December 28, 2019 compared to
the same period for 2018, and the segment had a loss from operations in fiscal 2019 of
$12.5 million.  Please tell us how you considered the factors pursuant to ASC 350-20-35-3
in determining that further impairment testing was not necessary given the decreases in
net revenues and gross profit for your capital equipment segment.  Additionally, please
tell us if the fair values of each of your reporting units are substantially in excess of their
carrying values.
Note 10. Revenue and Contract Liabilities, page 57
3.We note from your disclosure in Note 10 that you report revenue based on your reportable
segments and you believe that reporting revenue on this basis provides information about
how the nature, amount, timing, and uncertainty of revenue and cash flows are affected by
economic factors. However, we note that in your investor presentations and earnings calls,
you discuss the business in terms of certain end markets such as automotive, advanced
packaging, and memory, among others, as well as product categories such as your wire
bonder business and ball bonder business.  Additionally, we note that each of your two
reportable segments consists of six operating segments.  In light of this, it appears it may
be appropriate to disclose revenue on a further disaggregated basis.  Please tell us how
you considered the guidance in ASC 606-10-55-90 through 55-91 when determining the
appropriate level of disaggregation of revenue.

 FirstName LastNameLester Wong
 Comapany NameKulicke & Soffa Industries, Inc.
 February 28, 2020 Page 3
 FirstName LastName
Lester Wong
Kulicke & Soffa Industries, Inc.
February 28, 2020
Page 3

            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Melissa Gilmore at (202) 551-3777 or Claire Erlanger at (202) 551-
3301 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing