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CORRESP

 February 23, 2021

VIA EDGAR

 Jean Yu

United States Securities and Exchange Commission

 Division of
Corporate Finance, Office of Manufacturing

 100 F Street, NE

Washington, D.C. 20549

Re:
 Synaptics Incorporated

Form 10-K for the Fiscal Year Ended June 27, 2020

Filed on August 21, 2020

File No. 000-49602

Dear Ms. Yu:

 Synaptics Incorporated (the
“Company”) provides the following information in response to the comments contained in the correspondence of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated
February 2, 2021, relating to the aforementioned Form 10-K. For reference purposes, the text of your letter dated February 2, 2021, has been reproduced herein (in bold), with the Company’s
response below each numbered comment. Unless the context otherwise requires, references to “Synaptics,” “our,” “us,” or “we” mean Synaptics Incorporated on a consolidated basis with its wholly owned
subsidiaries.

 Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 39

1.
 Where you describe two or more business reasons that contributed to a material change in a financial
statement line item between periods, please quantify in future filings, where possible, the extent to which each change contributed to the overall change in that line item. In addition, where you identify intermediate causes of changes in your
operating results, also describe the reasons underlying the intermediate causes. For example, you disclose that net revenue was impacted by changes in units sold and average selling prices. Please quantify the extent to which the overall change in
revenues is attributable to each identified factor and explain in reasonable detail the reasons driving fluctuations in each factor. Ensure that your revised disclosures assist in satisfying the requirements of Item 303(a) of Regulation S-K and the three principal objectives of MD&A, as noted in SEC Release No. 33-8350:

•

 to provide a narrative explanation of a company’s financial statements that enables investors to see the
company through the eyes of management;

•

 to enhance the overall financial disclosure and provide the context within which financial information should
be analyzed; and

•

 to provide information about the quality of, and potential variability of, a company’s earnings and cash
flow, so that investors can ascertain the likelihood that past performance is indicative of future performance

 Response: We
acknowledge the Staff’s comments and confirm that in future filings we will quantify, where possible, the extent to which each business reason contributing to a material change in a financial statement line item contributed to the overall
change in that line item. In addition, where we identify intermediate causes of changes in our operating results, we confirm that we will describe the reasons underlying the intermediate causes, and we confirm that our revised disclosures will
assist in satisfying the requirements of Item 303(a) of Regulation S-K and the three principal objectives of MD&A, as noted in SEC Release No. 33-8350.

Synaptics Incorporated ● 1251 McKay ● San Jose, CA 95131 USA

Ph: 408.904.1100 ● Fax: 408. 904.1110

www.synaptics.com

 Notes to Consolidated Financial Statements, 4. Divestiture, page
F-17

2.
 We note that you divested your TDDI product line in April 2020. Based on the pro forma financial statements
provided in your Form 8-K filed April 16, 2020, it appears that TDDI was quantitatively material to your statements of operations, including revenues and operating,
pre-tax, and net income. Please tell us how you determined TDDI did not meet the criteria to qualify as discontinued operations under ASC 205-20-45-1B.

 Response: We acknowledge the Staff’s
comment and note that we determined that the divestment of our TDDI product line did not meet the criteria to qualify as discontinued operations under ASC 205-20-45-1B. In order to qualify as a discontinued operation, the disposal group must meet all of the following criteria:

•

 The disposal group must qualify as a component of an entity;

•

 The component of an entity (or group of components) meets the held for sale criteria, is disposed of by sale, or
is disposed of other than by sale (e.g., abandonment); and

•

 The component of an entity (or group of components) represents a strategic shift that has (or will have) a major
effect on an entity’s operations and financial results.

 We determined that the disposal did not represent a
strategic shift and the disposal group did not qualify as a component of an entity as the disposal group represented only a portion of our TDDI mobile product line and did not rise to the level of a component. Our mobile business consists of several
product groups that broadly share our touch and display technologies and engineering resources. We did not transfer our automotive, OLED or large TDDI products, or our discrete touch and discrete display driver product lines supporting LCD and OLED
semiconductor products for the mobile market.

 We determined that had the disposal group qualified as a component it would also have met
the held for sale criteria.

 Finally, as noted above, we determined that the sale did not represent a strategic shift that has (or will
have) a major effect on our operations and financial results. We continue to invest in TDDI technologies for automotive, OLED, and large touch and display applications, including continuing to invest in touch and discrete display driver products
supporting LCD and OLED semiconductor products for the mobile market. We also continue to invest in technologies for our mobile products and the divestiture of a portion of the TDDI mobile product line did not represent a strategic shift away from
that market or in developing future products we expect to introduce into the mobile market that we serve.

 12. Segment, Customers, and Geographic
Information, page F-33

3.
 Although you disclose you have a single reportable segment, we note that management refers to your product
lines during earnings calls as “businesses” and that the management team on your website includes Senior Vice President and General Manager positions for the PC & Peripherals, Wireless Connectivity, Multimedia, and Smart Sensing
and Display Divisions. Please tell us in sufficient detail how you determined that you have only one reportable segment. In doing so, tell us each operating segment you have identified under ASC 280-10-50-1 and provide us with the following information:

•

 Tell us the title and describe the role of the Chief Operating Decision Maker (“CODM”) and each of
the individuals that report to the CODM;

•

 Identify and describe the role of each segment manager;

•

 Tell us how often the CODM meets with his/her direct reports, the financial information the CODM reviews to
prepare for those meetings, the financial information discussed in those meetings, and who else attends those meetings;

•

 Describe the information regularly provided to both the CODM and the Board of Directors, and how frequently it
is prepared; and

•

 Explain to us the responsibilities of each Senior Vice President and General Manager identified above,
including to whom they report and how they are compensated.

 Response: We acknowledge the Staff’s comment and offer the following explanation
of our segment reporting position:

 Overview

FASB ASC 280-10-50-1
states that “an operating segment is a component of a public entity that has all of the following characteristics:

•

 It engages in business activities from which it may earn revenues and incur expenses (including revenues and
expenses relating to transactions with other components of the same public entity).

•

 Its operating results are regularly reviewed by the public entity’s chief operating decision maker to
make decisions about resources to be allocated to the segment and assess its performance.

•

 Its discrete financial information is available.”

The Company has analyzed its operating structure using the guidance provided in ASC 280-10-50 and, for the reasons described below and elaborated on in the remainder of this response, has determined that it has one operating segment and one reportable segment: the development, marketing, and
sale of semiconductor products used in electronic devices and products.

•

 The chief operating decision maker (“CODM”) relies on the Company’s consolidated financial
statements for decision-making purposes regarding the allocation of resources and assessment of performance.

•

 Twice annually, the CODM receives divisional financial information (by product line) during the annual operating
planning process (generally our June quarter) and the long-range planning process (generally our December quarter). We do not believe that the CODM’s receipt of this information twice annually rises to the level of regularly reviewed.

•

 The Company’s divisions engage exclusively in developing and supplying custom-designed semiconductor product
solutions to be marketed, sold, and supported by the Company’s centralized sales organization. The Company’s corporate operations are responsible for engaging with our supply chain partners in order to produce all of the Company’s
semiconductor product solutions. Classifying the Company’s divisions as additional operating segments would fail to reflect the resources and services expended by the Company separate from the divisions, would require imprecise allocations of
such resources and services, and would assume a level of division leader independence and authority that is not present within the Company.

The Company’s Organizational Structure

The Company develops, markets and sells semiconductor products used in electronic devices and products. The Company generates revenue from
three broad product categories: the mobile product applications market, the personal computing (“PC”) product applications market and the Internet of Things (“IoT”) product market. There are shared customer and vendor
relationships, and technologies, including manufacturing, assembly and test processes among the three broad market categories. The Company maintains four divisions supporting its product categories:

•

 The Smart Sensing and Display division is responsible for both integrated and discrete touch and display
semiconductor product solutions supporting the mobile product applications market and the IoT product market.

•

 The PC & Peripherals division is responsible for touchpad, fingerprint sensor, and interface
semiconductor product solutions supporting the PC product applications market and the IoT product market;

•

 The Wireless Connectivity division is responsible for integrated Wi-Fi
and Bluetooth solutions and satellite-based GPS and GNSS semiconductor product solutions supporting the IoT product market; and

•

 The Multimedia division is responsible for multimedia and audio semiconductor product solutions supporting the
IoT product market.

 The Company does not believe that the divisions are separate operating segments.

The Company manages and makes key operating decisions for all of its businesses centrally at its San Jose headquarters. The Company maintains
an organizational structure, separate from the divisions, that engages in sales, operations, strategy, silicon engineering, and other key operational functions such as finance, legal, human resources, and information technology, all of which

report directly to our Chief Executive Officer. The Company’s corporate operations are responsible for engaging with our supply chain partners in order to produce all of the Company’s
semiconductor product solutions across all divisions. The employees in the divisions are engaged in product development with respect to the particular focus of each such division while all other business functions are maintained outside the
divisions at the Company level.

 The Company has determined that its business structure, which centralizes all business functions in
organizations outside the divisions, is designed to maximize efficiency and synergies as a result of the substantial similarities in the Company’s customer base, supply vendors, and technologies. Our centralized sales organization together with
our centralized operations organization support all divisions driving customer orders and revenue opportunities and managing the intricacies and complexity of the supply chain to deliver our finished products to customers. Our strategic organization
works closely with the CODM to evaluate and assess opportunities for investment or divestment on behalf of the divisions. Our human resources, legal, finance, accounting, and information technologies organizations support the CODM and all the
divisions. The delineations between the Company’s divisions are based primarily on different categories of products in which our semiconductor products are designed into and used.

The CODM

 The
Company considers Michael Hurlston, its President and Chief Executive Officer, to be its CODM. The CODM manages the Company’s business and assesses its overall performance as a business as a developer, marketer and seller of semiconductor
products used in electronic devices and products. The Company’s major operational and financial decisions are made by the CODM, who makes decisions on the basis of the Company’s consolidated financial information, whereby the CODM is able
to evaluate the Company’s operating results to assess performance and allocate resources across the Company.

 The CODM has ultimate
decision-making authority over the key operating decisions across all product categories, including sales organization, operations, strategy, silicon engineering, and other functional areas in the organization such as finance, legal, human
resources, and information technology (subject, in certain cases, to the approval of the Company’s Board of Directors).

Individuals Reporting to the CODM

The list below describes the roles and responsibilities of the individuals who report to the CODM (the “Direct Reports”) as well as
how they are compensated. None of the below individuals has the authority to make operating decisions similar to those made by the CODM. Accordingly, none of the below individuals are the CODM or part of a group constituting the CODM in accordance
with ASC 280-10-50-05 through
280-10-50-9.

Senior Vice Presidents and General Managers

•

 Saleel Awsare serves as the Company’s Senior Vice President and General Manager, PC & Peripherals
Division. In such position, Mr. Awsare is responsible for engineering and development of our PC and peripheral product lines, which includes driving and approving tactical decisions aligning to corporate strategy, resource allocations and
management of those resources within the division.

•

 Alex Chou serves as the Company’s Senior Vice President and General Manager, Wireless Connectivity Division.
In such position, Mr. Chou is responsible for engineering and development of our wireless connectivity product lines, which includes driving and approving tactical decisions aligning to corporate strategy, resource allocations and management of
those resources within the division.

•

 Venkat Kodavati serves as the Company’s Senior Vice President and General Manager, Multimedia Division. In
such position, Mr. Kodavati is responsible for engineering and development of our multimedia product lines, which includes driving and approving tactical decisions aligning to corporate strategy, resource allocations and management of those
resources within the division.

•

 Janice Mori serves as the Company’s Senior Vice President and General Manager, Smart Sensing and Display
Division. In such position, Ms. Mori is responsible for engineering and development of our smart sensing and display product lines, which includes driving and approving tacti