SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
       August 18, 2014

Via E -mail

Brad Anderson
Chief Financial Officer
Amtech Systems, Inc.
131 South Clark Drive
Tempe, Arizona   85281

 Re: Amtech Systems, Inc.
  Form 10 -K for the fis cal year ended September  30, 201 3
  Filed December 11, 2013
  Form 1 0-Q for the quarterly  period  ended June 30, 2014
  Filed August 7,  2014
  File No. 000-11412

Dear M r. Anderson :

We have reviewed your filing s and have the following comment s. We have limited
our review to only your financial statements and related disclosures and do not intend to
expand our review to other portions of your documents.  In our comment s, we may ask you
to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten busine ss days  by providing the requested
information or by advising us when you will pr ovide the requested response.  If you do
not believe our comment s apply  to your facts and circumstances , pleas e tell us why in
your response.

After reviewing the information you provide in response to these  comment s, we
may have additional comments.

Form 10 -K for the fiscal year ended September 30, 2013

Item 7.  Management’s Discussion and Analysis of Financial Condition an d Results of
Operat ions

Liquidity and Capital Resources, page 33

1. We see that you generated 80% of net revenue outside of North America. Please
revise future filings to disclose the  amount of cash and cash equivalents as well as

Brad Anderson
Amtech Systems, Inc.
August 18, 2014
Page 2

 liquid investments held by your foreign s ubsidiaries at September 30, 2013  and
quantify the amount  that would not be available for use in the U.S.  without
incurring U.S taxes.

Consolidated Financial Statements

Note 1. Revenue Recognition, page 46

2. We see from your disclosure that you allocate revenue to multiple deliverables
equal to the total sales price less the greater of the (1) relative fair value of the
undelivered items and (2) all contingent portions of the sales agreement.   Please
explain to us how you apply FASB ASC 605 -25-30, which requires ar rangement
consideration to be allocated based on the relative selling price to all deliverables
in your multiple element arrangements. Please identify each unit of accounting
and discuss how you dete rmine the selling price for each deliverable  under FASB
ASC 605 -25-30-2.  Please also include clarifying disclosure in future filings.

Note 10.  Income Taxes, page 60

3. In future filings please provide the disclosures related to u ndistributed earnings of
foreign subsidiaries as required FASB ASC 740-30-50-2.

Form 10 -Q for the  quarter ly period ended June 30, 2014

Condensed Consolidated Financial Statements

Note 1.  Basis of Presentation, Warranty, page 11

4. We see that your warranty accrual significantly declined from $1.7 million at June
30, 2013 to $766,000 at June 30, 2014.   Please revise future filings to provide a
discussion of the reasons for changes in judgments or estimates that resulted in a
signifi cant decrease in your warranty accrual.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable  Exchange Act rules require.  Since the company
and its management are in possession of all facts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy of the disclosures they have made.

 In responding to our comments, pl ease provide a written statement from the
company acknowledging that:

 the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

Brad Anderson
Amtech Systems, Inc.
August 18, 2014
Page 3

  staff comments or changes to disclosure in response to staff comments do
not foreclose the Commission from taking any action with respect to the
filing; and
 the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

 You may contact Kristin Lochhead, Senior Accountant,  at (202) 551 -3664  or me
at (202) 551 -3676 if you have questions regarding comments on the financial statements
and related matters.  Please contact Martin James, Senior Assistant Chief Accountant, at
(202) 551 -3671  with any other questions.

Sincerely,

/s/ Brian Cascio

Brian Cascio
Accounting Branch Chief