United States securities and exchange commission logo
April 25, 2023
Lester Wong
Chief Financial Officer
Kulicke and Soffa Industries, Inc.
1005 Virginia Drive
Fort Washington, PA 19034
Re: Kulicke and Soffa
Industries, Inc.
Form 10-K for the
fiscal year ended October 1, 2022
Form 10-Q for the
quarterly period ended December 31, 2022
Response dated
April 12, 2023
File No. 000-00121
Dear Lester Wong:
We have reviewed your April 12, 2023 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
March 14, 2023 letter.
Form 10-K for the Fiscal Year Ended Ended October 1, 2022
Notes to Consolidated Financial Statements
Note 16: Segment Information, page 68
1. We note your response
to comment 2 and have the following comments:
Please expand on
how the aggregation of your operating segments is consistent with
the objective and
basic principles of ASC 280-10-10-1. In doing so, explain in
greater detail how
the aggregated operating segments are so similar that presenting
the information
separately would not significantly benefit an investor's understanding
of your performance
and future prospects. As part of your response, specifically
address the
aggregation within your Aftermarket Product and Services
Lester Wong
Kulicke and Soffa Industries, Inc.
April 25, 2023
Page 2
("APS") reportable segment of your non-machine business,
including Blades, Wedge
Bonder Consumables, and Capillaries, with your customer support
organization,
Spares and Services.
You indicate that the operating segments in your Capital
Equipment ("CE") and
APS reportable segments have long-term 5-year average gross
margins within a range
of approximately +/- 5% and +/-10%, respectively. You further
indicate that the APS
operating segments "have similar trends in sales growth" for the
5-year period from
2017 to 2022. Please provide us with the 5-year average gross
margins and 5-year
sales growth figures for each operating segment, as well as gross
margins and sales
by year within such periods.
Tell us if you considered any other measures in assessing
whether aggregated
operating segments had similar economic characteristics and, if
so, provide us with
your analysis and the related supporting data. In doing so, tell
us how you considered
segmental income from operations, the measure of segment
profitability used by your
CODM, in assessing whether or not your operating segments had
similar economic
characteristics. Provide us with a 5-year historical
quantification of each operating
segment's income from operations.
To the extent not addressed above, provide us with quantitative
information that helps
us assess which operating segments materially contribute to your
operating results.
You may contact Beverly Singleton at (202) 551-3328 or Andrew Blume at
(202) 551-
3254 with any questions.
FirstName LastNameLester Wong Sincerely,
Comapany NameKulicke and Soffa Industries, Inc.
Division of
Corporation Finance
April 25, 2023 Page 2 Office of
Manufacturing
FirstName LastName