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 January 14, 2026

Naixi Wu
Chief Financial Officer
indie Semiconductor, Inc.
32 Journey Suite #100
Aliso Viejo, CA 92656

 Re: indie Semiconductor, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Form 8-K Filed November 6, 2025
 Response Dated September 26, 2025
 File No. 001-40481
Dear Naixi Wu:

 We have reviewed your September 26, 2025 response to our comment letter
and have
the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our August
22, 2025 letter.

Form 8-K Filed November 6, 2025
Exhibit 99.1, page 1

1. We note your response to prior comment 6, including your statements that
you do not
 present GAAP gross profit or GAAP gross margin in your Consolidated
Statements of
 Operations because certain costs related to contract revenues are
expensed as incurred
 and included in research and development expenses and it is not
practicable to
 allocate such expenses to cost of sales. We also note you now believe
the adjusted
 non-GAAP gross profit and adjusted non-GAAP gross margin measures you
present
 should be categorized as Key Performance Metrics (KPMs) because: (1)
they are
 consistent with how you reflect your business in internal financial
statements; (2) they
 are consistent with how your leadership and Chief Executive Officer
operate and
 manage the business (including being used as a measurement metric your
annual
 January 14, 2026
Page 2

 incentive plan); and (3) they are part of the material quantitative
measures that your
 investors use to understand and evaluate your periodic financial
performance. Please
 more fully address the following:
 Based on the information you provided, it does not appear to us that
the measures
 you present should be categorized as KPMs. Although we acknowledge
KPMs
 and non-GAAP financial measures may overlap, based on the nature and
 calculation of the measures you present, we believe that the
measures meet the
 definition of a non-GAAP financial measure since they are numerical
financial
 metrics that exclude or include amounts from the most directly
comparable GAAP
 measures, regardless of whether the GAAP measures are in your
Consolidated
 Statements of Operations. In this regard it would not be appropriate
to present
 them without presenting, and reconciling to, the most directly
comparable GAAP
 measures, GAAP gross profit and GAAP gross margin, based on the
guidance in
 Items 10(e)(1)(i)(A) and (B) of Regulation S-K and Item 100(a) of
Regulation G.
 Based on the description of your business, including how contract
revenue,
 funding received from customers to develop certain products, and
product revenue
 are generated and, your statement that these activities "create a
library of
 knowledge for you to essentially generate revenue , it is not
clear to us how you
 determined that presenting non-GAAP performance measures, that
exclude
 research and development expenses, complies with the requirements of
Item 10(e)
 of Regulation S-K, Item 100(a) of Regulation G, and our response to
Question
 100.01 of the Non-GAAP CDIs.

 Please contact Dale Welcome at 202-551-3865 or Anne McConnell at
202-551-3709
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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