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CORRESP
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Amendment to CORRESP filed on 09/15/05 (Accession No.: 0001193125-05-185877)

 September 15,
2005

 VIA FACSIMILE and EDGAR

 Mr. Gary R. Todd,

   Reviewing Accountant,

     Mail Stop 6010,

       Division of Corporation Finance,

         Securities and Exchange Commission,

           450 Fifth Street,

             Washington, D.C. 20549

Re:

ChipMOS TECHNOLOGIES (Bermuda) LTD.

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

Forms 6-K for fiscal 2005

File No.
0-3116

 Dear Mr. Todd:

 This is in response to the Staff’s comment letter, dated August 18,
2005 (the “Comment Letter”), relating to our annual report on Form 20-F for the fiscal year ended December 31, 2004 (the “2004 Form 20-F”) (File No. 0-31106) which was filed with the Securities and Exchange Commission (the
“Commission”) on June 29, 2005 and Forms 6-K for the fiscal year 2005. As indicated in our letter dated August 30, 2005, we were not able to provide responses within 10 business days of the Staff’s comment letter. We are providing
full responses to the Staff’s comments herewith.

 Our
responses have been prepared to reflect facts, data and conditions in our business and operations as of the date of this letter or as of particular past dates as indicated. We are proposing the indicated changes in future filings in the spirit of
cooperation with the Staff, and not because we believe the 2004 Form 20-F was materially deficient or inaccurate. Accordingly, any changes implemented in future filings should not be taken as an admission that prior disclosure were in any way

 Mr. Gary R. Todd

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 deficient. Because the disclosure we
intend to include in our future filings will need to be drafted in light of the facts and circumstances relevant at the time of such future filings, we have not indicated in this letter proposed drafts of such disclosures.

 In connection with responding to the Staff’s comments, we wish to
acknowledge that:

•

we are responsible for the adequacy and accuracy of the disclosure in the filing;

•

the Staff’s comments or changes to disclosure in response to Staff’s comments do not foreclose the Commission from taking any action with respect to the filing; and

•

we may not assert Staff’s comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 For your convenience, we have included your
comments in this response letter in italicized form and keyed our responses accordingly. Unless otherwise indicated, the page number references in our response are to the 2004 Form 20-F. Our responses to the comments are as follows:

 Audited Financial Statements, beginning on page F-1

 Summary of Significant Differences between Accounting Principles Followed by the
Company and Accounting Principals Generally Accepted in the United States, page F-41

1.
We see that you consolidate Modern Mind and its subsidiary and ThaiLin Semiconductor. We also see that you own no shares in Modern Mind and hold a 27.6% interest in ThaiLin
Semiconductor. For US GAAP purposes please explain why it is appropriate to consolidate these entities. Identify and describe the basis in GAAP and explain how you applied the literature to your fact pattern.

 We wish to advise the Staff that we consolidate Modern Mind
Technology Limited (“Modern Mind”) (including its wholly-owned subsidiary, ChipMOS TECHNOLOGIES (Shanghai) LTD. (“ChipMOS Shanghai”)) and ThaiLin Semiconductor Corp. (“ThaiLin Semiconductor”) in reliance on Rule
3A-02(a) under Regulation S-X. Rule 3A-02(a) requires a company to consolidate an entity, notwithstanding the lack of majority ownership, if such consolidation is necessary to present fairly its financial position and results of operations because
of the

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 existence of a
parent-subsidiary relationship by means other than record ownership of voting stock.

 Although we do not have a majority ownership in either Modern Mind or ThaiLin Semiconductor, we possess the power to direct or cause the
direction of the management and policies of these companies by contract or otherwise and thereby have established a parent-subsidiary relationship over these two entities.

 We control Modern Mind through certain loan arrangements we have entered into with Modern Mind and its 100%
legal owner, Jesper Limited (“Jesper”). Under these arrangements, we have agreed to provide loans from time to time to Modern Mind in exchange for demand notes that can be converted into its common shares at any time. Payment under the
demand notes is fully and unconditionally guaranteed by Jesper and secured by a security interest in the entire equity interest in Modern Mind and ChipMOS Shanghai. Moreover, Jesper has granted us an irrevocable option, exercisable at any time, to
acquire the common shares of Modern Mind then owned by Jesper. We wish to advise the Staff that we have made detailed disclosures on the contractual arrangements among Jesper, Modern Mind and us under “Item 3. Key Information — Risk
Factors — Risks Relating to Countries in Which We Conduct Operations — The investments in Mainland China by our controlled consolidated subsidiary, Modern Mind, through ChipMOS Shanghai, and the related contractual arrangements may result
in Mosel violating ROC laws governing investment in Mainland China by ROC companies or persons. Any sanctions on Mosel as a result of any violation of ROC laws may cause Mosel to decrease its ownership in us significantly or cause Mosel to take
other actions that may not be in the best interest of our other shareholders”, “Item 3. Key Information — Risk Factors — Risks Relating to Countries in Which We Conduct Operations — Our current ownership structure and
contractual arrangements with Jesper Limited, Modern Mind and ChipMOS Shanghai may not be effective in providing operational control of our Mainland China operations”, “Item 4. Information on the Company — Our Structure and History
— Modern Mind Technology Limited and ChipMOS TECHNOLOGIES (Shanghai) LTD.” and “Item 10. Additional Information — Material Contracts”.

 As of December 31, 2004, we had provided an aggregate of US$82.8 million in loans to Modern Mind in exchange
for the demand notes in the same aggregate amount, accounting for 99% of the total liabilities of Modern Mind on that date. These demand notes would represent, immediately after the conversion, almost 100% of the then outstanding common shares of
Modern Mind at a conversion rate of US$1.00 for each common share of Modern Mind. Moreover, as of December 31, 2004, our chairman and director/chief executive officer, Shih-Jye Cheng, was the sole director of Modern Mind, and Shih-Jye Cheng and four

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 of our executive
officers comprised the entire board of directors of ChipMOS Shanghai, Modern Mind’s only, and wholly-owned, subsidiary. As a result of these arrangements, we have consolidated Modern Mind and ChipMOS Shanghai, to present fairly our financial
position and results of operations.

 As of
December 31, 2004, our 70.34% subsidiary, ChipMOS TECHNOLOGIES INC. (“ChipMOS Taiwan”), held a 30.08% interest in ThaiLin Semiconductor, and as the largest shareholder in ThaiLin Semiconductor, appointed four of the seven directors of
ThaiLin Semiconductor, including Shih-Jye Cheng, our chairman and director/chief executive officer, serving as its chairman, and Lafair Cho, serving also as its president. ChipMOS Taiwan was thereby in a position to control ThaiLin
Semiconductor’s operations, personnel and financial policies. As a result, we have consolidated ThaiLin Semiconductor to present fairly our financial position and results of operations.

2.
As a related matter, if you have consolidated Modern Mind and its subsidiary and ThaiLin Semiconductor in reliance on FIN 46, show us that your financial statements present all
of the relevant disclosures required by that guidance.

 We wish to advise the Staff that we did not rely on FIN 46 for consolidation of Modern Mind and its subsidiary and ThaiLin Semiconductor, as indicated in our response to the question above.

3.
We see that you recognize revenue at shipment and that shipment also includes shipment to your warehouse for customers using your warehousing services. Accordingly, it appears
that you recognize revenue on a bill and hold basis. For US GAAP purposes, provide us an analysis demonstrating that your revenue policy for shipments to your internal warehouse is appropriate. Show us that you have appropriately applied the
guidance from SAB Topic 13 for bill and hold arrangements.

 We wish to advise the Staff that we recognize some revenue on a bill and hold basis. Our primary business is the provision of value-added assembly and testing services, and ownership of the goods on which we perform
testing and/or assembly services remains with our customers throughout the period when these goods are in our possession, both while we perform testing and/or assembly, and, during any subsequent period in which we hold such goods in storage at the
request of our customers. In certain circumstances, our customers choose not to request immediate delivery of the goods due to shortage of storage, and, as part of our value added services, we provide them warehousing services by delivering the
goods to our internal warehouses after completion of testing and/or assembly

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 services. Set forth
below is our detailed analysis of the seven criteria and five factors of SAB Topic 13:

 Seven criteria of SAB Topic 13

1.
The risks of ownership must have passed to the buyer.

 We are of the view that the risks of ownership remain with our customers throughout the period when these goods are in our possession. The agreements we
had with customers generally contain the language to the effect that ownership of the goods remains with our customers and that we have been engaged to perform the testing and/or assembly services. As a result, during and after the
performance of our testing and/or assembly services have been completed, all risks of ownership are with our customers. In addition, some of our customers have entered into separate warehouse leasing arrangements with us and these products are
stored in the warehouse pursuant to the leases.

2.
The customer must have made a fixed commitment to purchase the goods, preferably in written documentation.

 Our customers have made a fixed commitment for our testing and/or assembly
services, as evidenced by their written agreements with us and/or the purchase orders placed with us.

3.
The buyer, not the seller, must request that the transaction be on a bill and hold basis. The buyer must have a substantial business purposes for ordering the goods on a bill and
hold basis.

 Our customers who request our
provision of short-term warehousing services may do so either through separate warehousing contracts entered into with us, or on the basis of requests they make at the time of completion of the assembly or testing of their goods, in order to
facilitate efficient delivery of goods to their ultimate end users.

4.
There must be a fixed schedule for delivery of the goods. The date for delivery must be reasonable and must be consistent with the buyer’s business purposes (e.g., storage
periods are customary in this industry).

 We
deliver the finished goods to our customers upon their request to satisfy their business needs.

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5.
The seller must not have retained any specific performance obligations such that the earning process is not complete.

 Under our agreements with customers, we do not perform any additional
services with respect to those goods other than storage and delivery after these goods have been delivered to our warehouses.

6.
The ordered goods must have been segregated from the seller’s inventory and not be subject to being used to fill other orders.

 We have segregated these goods from our inventory by storing them at our
storage warehouses with separate identifications, such as different storage codes, and they are not subject to being used to fill other orders.

7.
The product must be complete and ready for shipment.

 The goods which we have stored, at the request of our customers, in our warehouses are goods on which we have performed all testing and/or assembly
services, and which are complete and ready for shipment.

 Five factors of SAB 13

1.
The date by which the seller expects payment, and whether the seller has modified its normal billing and credit terms for this buyer.

 We generally expect payment within 60 days after month end and our invoicing
process and payment terms do not differentiate between customers who request immediate delivery of their goods or those who request that we provide short-term warehousing services after completion of testing and/or assembly services.

2.
The seller’s past experiences with and pattern of bill and hold transactions.

 During the years ended December 31, 2002, 2003 and 2004, we have not experienced differences in the collection of accounts
receivables from customers who requested immediate delivery and those who requested provision of our warehousing services.

3.
Whether the buyer has the expected risk of loss in the event of a decline in the market value of goods.

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 Based on the terms of
our agreements with these customers, our customers retain the ownership of these goods and therefore are responsible for any loss in the event of a decline in the market value of goods.

4.
Whether the seller’s custodial risks are insurable and insured.

Our custodial risks are insurable and have been insured under our property damage insurance policy with a third-party insurance company.

5.
Whether extended procedures are necessary in order to assure that there are no exceptions to the buyer’s commitment to accept and pay for the goods sold (i.e., that
the business reasons for the bill and hold have not introduced a contingency to the buyer’s commitment).

 No extended procedures are necessary to assure that there are no exceptions to the buyer’s commitment to accept and pay for the goods sold.

4.
We see that recoveries of the allowance for inventories are reported as income for ROC GAAP purposes. For US GAAP purposes, inventory reserves or allowances are not reversed
until the affected inventory is disposed. Tell us how your method is faithful to the requirements of SAB Topic 5-BB. Future filings should present disclosure about any US/ROC GAAP difference for this matter.

 We wish to advise the Staff that the reversal of inventory
reserves or allowances was made as the affected inventory was disposed of as of December 31, 2004, which method we believe complies with the requirements of SAB Topic 5-BB.

 We note the Staff’s comment and wish to advise the Staff that disclosure about any US/ROC GAAP
differences for this matter will be included in future filings.

5.
In Note 28(b) we see an unrealized loss on equity securities totaling approximately $7 million. The disclosure suggests that the securities have been impaired for more than
twelve months. For US GAAP purposes tell us why there is no other than temporary impairment. Please provide a full explanation of the basis for your conclusions. Also fully describe how you considered the requirements of US GAAP for this matter.

 We wish to advise the Staff
that the word “not” was inadvertently inserted before “deemed to be …” in the sentence which reads, “The following table shows the gross unrealized losses and fair value of short-term investments with

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 unrealized losses that
are not deemed to be other-than-temporarily impaired, aggregated by investment category that individual securities have been in a continuous unrealized loss position, at December 31, 2004” in Note 28(b) (italics added), and thereby it
was mistakenly indicated that the US$7 million was not other than temporary