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SEC Comment Letter 0000000000-23-001140 to ALPHA & OMEGA SEMICONDUCTOR Ltd (AOSL)

ALPHA & OMEGA SEMICONDUCTOR Ltd
Date: Feb. 3, 2023 · CIK: 0001387467 · Accession: 0000000000-23-001140

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File numbers found in text: 001-34717

Date
February 3, 2023
Author
Andi Carpenter
Form
UPLOAD
Company
ALPHA & OMEGA SEMICONDUCTOR Ltd

Letter

United States securities and exchange commission logo February 3, 2023 Yifan Liang Chief Financial Officer and Corporate Secretary Alpha and Omega Semiconductor Limited Clarendon House, 2 Church Street Hamilton HM 11 Bermuda Re:Alpha and Omega Semiconductor Limited Form 10-K for the Fiscal Year Ended June 30, 2022 Form 10-Q for the Fiscal Quarter Ended September 30, 2022 Filed September 20, 2022 and November 7, 2022 File No. 001-34717 Dear Yifan Liang: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-Q for the Quarterly Period Ended September 30, 2022 Notes to Condensed Consolidated Financial Statements Segment and Geographic Information, page 27 1.We note your discussion of revenues by Computing, Consumer, Communications, and Power Supply and Industrial in your earnings call for the fiscal quarter ended September 30, 2022. In future filings, please provide disaggregated revenue by category, consistent with you earnings calls. Refer to Paragraphs 5 and 6 of ASC 606-10-50 for guidance.

Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 35 2.If your operations have experienced or are experiencing inflationary pressures or rising costs, please expand to identify the principal factors contributing to the inflationary

FirstName LastNameYifan Liang Comapany NameAlpha and Omega Semiconductor Limited February 3, 2023 Page 2 FirstName LastName Yifan Liang Alpha and Omega Semiconductor Limited February 3, 2023 Page 2 pressures the company has experienced and clarify the resulting impact to the company. Please also revise to identify actions planned or taken, if any, to mitigate inflationary pressures. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Andi Carpenter at 202-551-3645 or Kevin Stertzel at 202-551-3723 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing

Show Raw Text
United States securities and exchange commission logo
February 3, 2023
Yifan Liang
Chief Financial Officer and Corporate Secretary
Alpha and Omega Semiconductor Limited
Clarendon House, 2 Church Street
Hamilton HM 11 Bermuda
Re:Alpha and Omega Semiconductor Limited
Form 10-K for the Fiscal Year Ended June 30, 2022
Form 10-Q for the Fiscal Quarter Ended September 30, 2022
Filed September 20, 2022 and November 7, 2022
File No. 001-34717
Dear Yifan Liang:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-Q for the Quarterly Period Ended September 30, 2022
Notes to Condensed Consolidated Financial Statements
Segment and Geographic Information, page 27
1.We note your discussion of revenues by Computing, Consumer, Communications, and
Power Supply and Industrial in your earnings call for the fiscal quarter ended September
30, 2022.   In future filings, please provide disaggregated revenue by category, consistent
with you earnings calls.  Refer to Paragraphs 5 and 6 of ASC 606-10-50 for guidance.

Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 35
2.If your operations have experienced or are experiencing inflationary pressures or rising
costs, please expand to identify the principal factors contributing to the inflationary

 FirstName LastNameYifan Liang
 Comapany NameAlpha and Omega Semiconductor Limited
 February 3, 2023 Page 2
 FirstName LastName
Yifan Liang
Alpha and Omega Semiconductor Limited
February 3, 2023
Page 2
pressures the company has experienced and clarify the resulting impact to the company.
Please also revise to identify actions planned or taken, if any, to mitigate inflationary
pressures.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Andi Carpenter at 202-551-3645 or Kevin Stertzel at 202-551-3723
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing