SecProbe.io

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Mail Stop 6010

      July 8, 2005

Mr. Roland PudeIko
Executive Director, Chief Executive Officer and President
Dialog Semiconductor PLC.
Building 15 and 5C
Neue Strasse 95
D-73230 Kirchheim/Teck-Nabern, Germany

	RE:	Dialog Semiconductor PLC
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed April 15, 2005

Dear Mr. Vegh:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filings to the issues we have
addressed in our comment.  Where indicated, we think you should
revise future filings in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 20-F for the fiscal year ended December 31, 2004

Financial Statements

Note 2. Summary of Significant Accounting Policies

Revenue Recognition

1. Please tell us and revise future filings to disclose more
details
of your revenue recognition accounting policy for all significant
products and services. The policy should also address rights of
return, customer acceptance, sales incentives, post shipment
obligations and other special terms or arrangements with
distributors
that could impact revenue recognition.

Use of Estimates

2. You disclosed that the company increased the useful life of its
test equipment from five to eight years. Please tell us and revise
future filings to disclose the reasons for the change in estimate
and
the effect of the change on reported net income/loss.

Note 4. Recovery of Investment

3. We note the recovery of previously written-off investments.
Please
tell us and revise future filings to include the following
additional
disclosures:
* Describe the facts and circumstances leading to the investment
impairment including the specific events that caused the
impairment
and when those events occurred;
* The amount written-off in 2001;
* Disclose the method and significant assumptions used to
determine
the amount written-off and the subsequent amounts recovered.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

	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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

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

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Patrick Enunwaonye, Staff Accountant, at
(202)
551-3645 or me, at (202) 551-3676 if you questions regarding
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Martin James, Senior Assistant Chief
Accountant, at (202) 551-3671 with any other concerns.

								Sincerely,

								Brian Cascio
								Accounting Branch Chief
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Mr. Roland PudeIko
Dialog Semiconductor PLC
July 8, 2005
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