SecProbe.io

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Mail Stop 6010

October 14, 2005

Shih-Jye Cheng, Chairman and Chief Executive Officer
ChipMOS Technologies (Bermuda) Ltd.
No. 1,  R & D Road 1
Hsinchu Science Park
Hsinchu, Taiwan
Republic of China

	Re:	ChipMOS Technologies (Bermuda) Ltd.
		Form 20-F for the fiscal year ended December 31, 2004
		Forms 6-K for fiscal 2005
		File No.  0-31106

Dear Mr. Cheng:

      We have reviewed the information and proposed disclosures
filed
on September 21, 2005           and have the following additional
comment.  We have limited our review to only your financial
statements and related disclosures and will make no further review
of
your documents.  Where indicated, we think you should revise your
documents in response to this comment in all future filings with
the
Commission.  If you disagree, we will consider your explanation as
to
why our comment is inapplicable or a revision is unnecessary.
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.

Mr. Shih-Jye Cheng
ChipMOS Technologies (Bermuda) Ltd.
October 14, 2005
Page 2

Form 6-K For the Month of August 2005

1. We see that the earnings release for the second quarter of 2005
presents a non-GAAP measure of earnings per share excluding
certain
expenses.  If you present such non-GAAP measures in future press
releases, please also present all of the relevant disclosures
specified by Item 10(e) to Regulation S-K and Question 8 to the
document "Frequently Asked Questions Regarding the Use of Non-GAAP
Financial Measures."

      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please understand that we may have additional comments after
reviewing your responses to our comments.

      You may contact Jeanne Bennett at (202) 551-3606, or me at
(202) 551-3605, if you have questions regarding our comments.  In
our
absence you may contact Brian R. Cascio, Accounting Branch Chief,
at
(202) 551-3676

      Sincerely,

      Gary R. Todd
								Reviewing Accountant

Copy to:	Sami Farhad, Esq.
		Sullivan & Cromwell in Hong Kong
		(852) 2522-2280

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