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CORRESP
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CORRESP

 September 9, 2020

 U.S.
Securities and Exchange Commission (“Commission” or “Staff”)

 c/o Ms. Melissa Raminpour and Ms. Heather Clark

Division of Corporation Finance

 Office of Manufacturing

Washington, DC 20549

Re:
 Silicon Motion Technology Corporation

Form 6-K furnished April 29, 2020

Form 6-K furnished July 30, 2020

File No. 000-51380

Dear Ms. Raminpour and Ms. Clark:

 Reference is made
to the letter received from the Commission dated August 25, 2020 regarding Form 6-Ks dated April 29, 2020 and July 30, 2020 of Silicon Motion Technology Corporation (the “Company”).

 For your convenience, we have included your comments in this response letter in bold form and keyed our response accordingly. The Company’s response
to the comments is as follows.

 Form 6-K furnished July 30, 2020

Comment:

 1. We note from your
response to our prior comment 3 that you will change your presentation in future filings to present your non-GAAP measures “without appearing to be a full non-GAAP
income statement.” However, we note that your presentation did not change from your Q1 2020 results furnished on April 29, 2020 to your Q2 2020 results furnished on July 30, 2020, after the date of our letter on July 9, 2020. In
this regard, please provide us with your proposed disclosure in future Forms 6-K.

 Response:

 We acknowledge the Staff’s comments and respectfully note that non-GAAP presentation were not revised in
our Q2 2020 results as we replied to the Commission on August 14th, after the release of our Q2 2020 results on July 30th. In our reply, we agreed to change in future filings the presentation of non-GAAP
measures without appearing to be a full non-GAAP income statement. We provide as an exhibit to this letter our proposed revised disclosure in future Forms 6-K.

8F, #36 Taiyuan St., Jhubei, Hsinchu 30265, Taiwan

Tel: +886-3-552-6888

Fax: +886-3-552-6988

www.siliconmotion.com

 Comment:

2. We note your response to our prior comment 4 that you will “discontinue the presentation of FCI divestiture adjustments in
subsequent periods when for sequential or year-after- year comparisons, past periods no longer include FCI operating results and the gain from divestiture.” However, we continue to believe that as the FCI divested operations did not meet the
criteria for being presented as discontinued operations pursuant to ASC 205-20, your non-GAAP measures appear to substitute individually tailored recognition and
measurement methods for those of GAAP. Therefore, as originally stated, please revise your non-GAAP presentations to comply with Question 100.04 of the Non-GAAP
C&DIs by removing the FCI divestiture adjustments. Please be advised that the revenue example discussed in Question 100.04 is only one example of a tailored measure. Note that alternatively, you may adjust for just the gain from the divestiture,
given that it was a one-time, non-cash charge.

 Response:

 We acknowledge the Staff’s comments that FCI divestiture adjustments included in our non-GAAP measures
could be construed as an individually tailored accounting principle and will remove this from future non-GAAP presentations. We will instead provide a summary of the impact on individual line items of the FCI
divestiture separately so investors can reconcile with our previous non-GAAP disclosures and continue to evaluate our business consistently without FCI. Please refer to the exhibit to this letter for our
proposed presentation in future Forms 6-K.

 Should you have any questions or wish to discuss the foregoing in
further detail, please feel free to contact the undersigned.

Sincerely,

 SILICON MOTION TECHNOLOGY

CORPORATION

By

 /s/ Riyadh Lai

Riyadh Lai, Chief Financial Officer

 2

 Exhibit

Silicon Motion Technology Corporation

Reconciliation of GAAP to Non-GAAP Operating Results

(in thousands, except percentages and per ADS data, unaudited)

For Three Months Ended

For the Six Months Ended

Jun. 30,

Mar. 31,

Jun. 30,

Jun. 30,

Jun. 30,

2019

2020

2020

2019

2020

($)

($)

($)

($)

($)

 Gross profit (GAAP)

46,129

63,892

68,394

93,748

132,286

 Gross margin (GAAP)

46.7
%

48.1
%

50.0
%

48.4
%

49.1
%

 Stock-based compensation (A)

7

38

3

114

41

 SSD solutions restructuring

4,985

—

—

4,985

—

 Gross profit (non-GAAP) (B)

51,121

63,930

68,397

98,847

132,327

 Gross margin (non-GAAP) (C)

51.7
%

48.2
%

50.0
%

51.1
%

49.1
%

 Operating expenses (GAAP)

33,851

39,798

38,255

73,477

78,053

 Stock-based compensation (A)

(219
)

(2,444
)

(243
)

(4,515
)

(2,687
)

 Amortization of intangible assets

(255
)

—

—

(510
)

—

 Litigation expense

—

—

—

2

—

 Operating expenses (non-GAAP) (B)

33,377

37,354

38,012

68,454

75,366

 Operating profit (GAAP)

12,278

24,094

30,139

20,271

54,233

 Operating margin (GAAP)

12.4
%

18.1
%

22.0
%

10.5
%

20.1
%

 Total adjustments to operating profit

5,466

2,482

246

10,122

2,728

 Operating profit (non-GAAP) (B)

17,744

26,576

30,385

30,393

56,961

 Operating margin (non-GAAP) (C)

18.0
%

20.0
%

22.2
%

15.7
%

21.1
%

 Non-operating income (expense) (GAAP)

14,727

1,267

1,187

16,816

2,454

 Foreign exchange loss (gain), net

68

481

142

(425
)

623

 Gain on disposal of long-term investments

(12,904
)

—

—

(12,904
)

—

 Non-operating income (expense) (non-GAAP) (B)

1,891

1,748

1,329

3,487

3,077

 Net income (GAAP)

26,484

25,915

28,211

34,756

54,126

 Total pre-tax impact of
non-GAAP adjustments (B)

(7,370
)

2,963

388

(3,207
)

3,351

 Income tax impact of non-GAAP adjustments (B)

(79
)

(524
)

2

(758
)

(522
)

 Net income (non-GAAP) (B), (C)

19,035

28,354

28,601

30,791

56,955

 Earnings per diluted ADS (GAAP)

$
0.75

$
0.74

$
0.80

$
0.98

$
1.54

 Earnings per diluted ADS (non-GAAP) (B),
(C)

$
0.54

$
0.80

$
0.81

$
0.87

$
1.62

 3

 Shares used in computing earnings per diluted ADS (GAAP)

35,536

35,246

35,164

35,505

35,147

 Non-GAAP Adjustments

32

63

36

63

49

 Shares used in computing earnings per diluted ADS
(non-GAAP)

35,568

35,309

35,200

35,568

35,196

 (A) Excludes stock-based compensation as follows:

 Cost of Sales

7

38

3

114

41

 Research & development

112

1,655

118

2,939

1,773

 Sales & marketing

70

335

85

678

420

 General & administrative

37

454

40

898

494

 (B) FCI divestiture items previously excluded from
non-GAAP:

 Revenue

4,566

—

—

10,359

—

 Gross Profit

2,597

—

—

5,687

—

 Operating Expenses

2,158

—

—

8,542

—

 Operating Profit(Loss)

439

—

—

(2,855
)

—

 Non-Operating Income(Expense)

(4
)

—

—

9

—

 Taxes

3

—

—

8

—

 Net income(Loss)

432

—

—

(2,854
)

—

 EPS

0.01

—

—

(0.08
)

—

 (C) Reconciliation with previous non-GAAP
disclosures:

 Revenue (non-GAAP) less FCI

94,280

132,769

136,811

183,181

269,580

 Gross Margin (non-GAAP) less FCI

51.5
%

48.2
%

50.0
%

50.9
%

49.1
%

 Operating Margin (non-GAAP) less FCI

18.4
%

20.0
%

22.2
%

18.2
%

21.1
%

 Earnings per diluted ADS (non-GAAP) less FCI

$
0.52

$
0.80

$
0.81

$
0.95

$
1.62

 4