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CORRESP

 April 2, 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

Response Dated February 23, 2021

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 March 12,
2021, relating to the aforementioned Form 10-K. For reference purposes, the text of your letter dated March 12, 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.

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

1.
 We have read your response to comment 2, noting that you determined the TDDI product line disposal did not
qualify as a discontinued operation since it did not qualify as a component of an entity and did not represent a strategic shift that has or will have a major effect on your operations and financial results. Please address the following comments:

 Response: We acknowledge the Staff’s comments and offer the following responses.

•

 Explain in further detail how you determined the disposed TDDI product line did not represent a component of
an entity. Considering you previously provided pro forma financial statements reflecting the impact, it appears that the operations and cash flows could be clearly distinguished, operationally and for financial reporting purposes, from the rest of
your business. We also note that you refer to the disposed entity as a “business” within the aforementioned Form 8-K, on page 40 of your Form 10-K, and on page
31 of your Form 10-Q for the quarterly period ended December 26, 2020.

Under ASC 205-20, a component of an entity comprises operations and cash flows that can be clearly
distinguished, operationally and for financial reporting purposes, from the rest of the entity. A component of an entity may be a reportable segment or an operating segment, a reporting unit, a subsidiary or an asset group.

We initially determined that our disposal group did not represent a component as it represented only a portion of a product line within a
component. Our divestiture was comprised of certain TDDI products that represented only a subset of our TDDI product line. The TDDI technology is used broadly across several products and not exclusively in the disposed mobile TDDI products.

We evaluated the requirements for filing pro forma financial statements under Regulation S-X Article 11
and determined that under the significant subsidiary rules the disposition did not meet the asset or income threshold tests (<5% under both tests), but it did initially meet the investment test threshold as a result of the estimated proceeds
being slightly over 10% of our fiscal 2019 year-end total assets. Accordingly, we prepared pro forma financial statements to comply with the pro forma financial statement disclosure requirements under
Regulation S-X Article 11.

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

 Ph: 408.904.1100 ● Fax: 408. 904.1110

www.synaptics.com

 Considering these factors in the aggregate, we acknowledge that the disposed mobile TDDI
products could be viewed as a component.

•

 Explain in further detail how you determined that the disposal did not represent a strategic shift that has or
will have a major effect on your operations and financial results. Based on your pro forma financial statements, we note that the disposal represented approximately 22% your fiscal 2019 revenues and over half of your net income for the six month
interim period ended December 28, 2019. We further note on page 31 of your most recent Form 10-Q that there was a 49% and 39.2% decline in your mobile product application net revenues for the three and
six months ended December 26, 2020, respectively, that you primarily attribute to the sale of your TDDI business.

The determination of a strategic shift that has or will have a major effect was based on management’s judgment and analysis, as there is
no bright line test set out in Subtopic 205-20. The Company does not, and did not at the time, believe the sale to be a strategic shift in its business plans, since following the disposition the Company
continues to pursue market share and product development in mobile smartphones applications, LCD based display technologies, and integrated touch and display products, and we continue to service substantially the same customer base as those who
purchased products related to the disposed assets.

 As part of the natural technology cycle in the semiconductor industry, particularly in
the mobile product market, many products do experience significant sales increases that are expected to significantly diminish over a relatively short time period. Our TDDI mobile products were no exception to this cycle. The Company is in a
constant state of investing and developing new and derivative products to meet the evolving needs of its end customers as their technology continues to change to keep up with changes in market requirements. The sale of a subset of these TDDI mobile
product SKUs were part of the Company’s natural technology cycle and not a strategic shift as we continue to invest in the TDDI technology and continue to sell TDDI product with this technology subsequent to the divesture.

Quantitatively, the mobile TDDI product line revenue was approximately 22% of the Company’s total revenue in fiscal 2019, declining to
approximately 18% of total revenue through the first six months of fiscal 2020. The third quarter of fiscal 2020 was the last full quarter with revenue from the disposed mobile TDDI product line, and revenue during that quarter further declined to
only approximately $41.2 million, or approximately 13%. Further, at the time of the disposition, the Company believed that the revenue from products related to the disposed assets would soon be less than 10% of the Company’s sales.
Accordingly, when viewed in the context of this declining revenue, the relative importance of this product line to the Company further supported the conclusion that it was not a change in the Company’s strategic direction.

In addition, as demonstrated in the pro forma financial statements with respect to the disposition, the Company’s research and development
investment decreased from an annualized rate of $46.9 million in fiscal 2019 to an annualized rate of $23.8 million, or by almost 50%, while selling general and administrative costs also decreased by approximately 15% on an annualized
basis. Although the reduction in investment into the divested product line temporarily increased its short-term profitability during the interim periods of fiscal 2020, the level of profitability of the disposed mobile TDDI product line in the six-month interim period ended December 28, 2019, was not sustainable long-term in relation to the expected impact to the consolidated results, and therefore we do not believe such profitability should be
extrapolated upon when assessing the impact in subsequent periods.

 We also noted that as a result of working with our external valuation
firm applying standard valuation practices, $12 million of goodwill was allocated to the disposed TDDI mobile product line. This accounted for less than 3% of total pre-disposition goodwill on our balance
sheet, which quantitatively would not qualify as a major effect in the Company’s view.

 Finally, the quantitative data presented in
the pro forma financial statements, while accurate, does not reflect our internal expectations of shrinking revenue from this product line that was marginally profitable if built around a long-term competitive cost structure. This, coupled with the
other qualitative factors described above, drove our conclusion that the disposal did not represent a strategic shift that has or will have a major effect on our operations and financial results.

As indicated in our Form 8-K filed on April 16, 2019, at the time of the announcement, we
determined that the business met the held for sale criteria as prescribed by ASC 360-10-45-9, but did not meet the criteria to
qualify as a discontinued operation. We believe our interpretation of the guidance and related conclusion are consistent with the applicable accounting rules and guidance under GAAP.

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

 Ph: 408.904.1100 ● Fax: 408. 904.1110

www.synaptics.com

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

 Response: We acknowledge the Staff’s comments and offer the following responses.

2.
 You indicate in your response to comment 3 that the CODM has ultimate decision-making authority over the key
operating decisions across all product categories, as well as other areas in the organization. Please describe the key operating decisions, who makes these decisions, and how performance is assessed and how resources are allocated. Additionally,
tell us what financial information is used by the CODM in making these key operating decisions. As part of your response, please provide examples.

Response: The Company considers Michael Hurlston, its President and Chief Executive Officer, to be its chief operating decision maker
(“CODM”). Mr. Hurlston, as CODM, in his ability to allocate resources, set the annual operating plan, and assess performance, has ultimate decision-making authority over all key strategic and operating decisions, including the
allocation of resources among the product categories and administrative and functional units and expenditures therein, restructuring activities, product roadmaps and sales strategies, manufacturing strategy and use of third-party foundries, the
geographic footprint of Company facilities and offices, overall headcount, Company financial performance targets, and mergers, acquisitions and divestitures.

A.
 To inform his decision-making regarding the allocation of resources, the CODM regularly reviews and relies on
the following:

(i)
 Quarterly consolidated financial statements that include a consolidated GAAP and
Non-GAAP Income Statement, consolidated Balance Sheet, consolidated Statement of Cash Flows, and relevant supporting financial information that are presented on a consolidated basis only;

(ii)
 Monthly updates on sales trends and new sales opportunities presented at a customer level; and

(iii)
 Monthly updates on the status of engineering projects.

As an example, the CODM reviewed consolidated financial statements, listened to investor feedback, and reviewed competitive benchmarks when he
joined the Company in early fiscal 2020 to set a goal to increase non-GAAP gross margin through the reduction of costs, process improvements, and overall spending. He then set spending targets on a
Company-wide basis in fiscal 2020 and 2021 and allocated resources to the divisions based on those targets. As another example, the CODM in early fiscal 2021 reviewed the Company-wide revenue forecast, external market forecasts, and market share to
determine that inorganic revenue expansion would be a productive strategy for the Company. He tasked each division and the corporate development function with identifying acquisition opportunities that would expand revenue without hindering the
Company’s ability to achieve its non-GAAP margin goal. The result of the review was the allocation by the CODM of resources to two divisions to acquire DisplayLink Corporation and to acquire certain
assets and license certain intellectual property from Broadcom, Inc., respectively, both of which represent acquisitions of semiconductor technology-based products.

B.
 Annually, the CODM reviews non-consolidated financial information as
part of the following processes:

(i)
 The Company’s annual operating planning process, which is designed around a
one-year time horizon, is performed once a year to set the Company’s budget for the next fiscal year. All of the CODM’s direct reports present their resource proposals for the next fiscal year. Their
proposals are reviewed and evaluated under a rigorous process and then modified and subsequently approved by the CODM. During the review process, the CODM sets a target budget for each of his direct report’s authorized spending levels,
expectation for sales goals, and target profitability goals where relevant. Finally, actual results from the prior fiscal year that are reviewed and compared to the prior fiscal year’s annual operating plan and approved by the CODM. This is the
only time that the disaggregated results are evaluated against target by the CODM, and therefore such results are not regularly reviewed.

(ii)
 The Company’s long-range planning process, which is designed around a three-year time horizon, is
performed once a year to assess the Company’s mid- to longer-term competitive market position. The CODM reviews and discusses competitive dynamics of the marketplace within each disaggregated product
category and future sales opportunities for the Company’s existing and roadmap products. The review includes a forecasted operating statement for the Company that is prepared by the Finance department as a point-in-time estimate that is not updated or provided outside of the annual long-range planning process. No resource allocation decisions are made during this process.

As noted, the financial information in the annual operating plan and the long-range plan are reviewed on an annual basis by the CODM and not
used on a quarterly basis or to assess performance throughout the year. ASC Paragraph 280-10-50-1b requires the operating results
to be regularly reviewed by the CODM in order to meet the operating segment criteria.

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

 Ph: 408.904.1100 ● Fax: 408. 904.1110

www.synaptics.com

3.
 We note the reference to your annual operating and long-range planning processes. Please explain to us how
budgets are prepared, who approves the budget at each step of the process, the level of detail discussed and individuals that participate at each step, and the level at which the CODM makes changes to the budget. Also, explain your process to assess
performance against budget, including the level at which this assessment is made, the frequency, and the individuals involved in that process. In this regard, we note from your response that you prepare internal quarterly financial reports on a
divisional basis.

 Response: The Company prepares its annual operating plan on an annual basis through the
following process: the Finance department prepares an operating budget proposal for each of the CODM’s direct reports, including the division general managers and the other corporate functional team leaders. The CODM’s direct reports then
present their budget proposals to the CODM, who critically reviews the plans, asks probing questions, and raises issues for consideration and follow up during an iterative process that runs over a two to four week period. The CODM then
evaluates the input from his direct reports and from the Finance department to establish corporate goals designed to address the competitive marketplace. The CODM will approve the final consolidated annual operating plan once all questions and
issues have been appropriately addressed within the framework of the Company’s overall corporate strategy (as described in point B(i) in our response to Comment 2 above).

The Company’s long-range planning process (as described in point B(ii) in our response to Comment 2 above), which is designed around
a three-year time horizon, is performe