November 5, 2010

VIA FACSMILE AND EDGAR

Ms. Barbara Jacobs

Assistant Director

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

                        RE: GigaMedia Limited (File no. 0-30540) Form 20-F for the Fiscal Year Ended December 31, 2009 Filed June 30, 2010 Request for Extension to Comment Letter Response

Dear Ms. Jacobs:

I refer to our telephone call on November 5, 2010.  GigaMedia Limited (the “Company”) confirms that it will respond to the comments of the Staff set forth in the Staff’s letter dated October 21, 2010 (the “Comment Letter”) no later than November 15, 2010 and hereby requests an extension of time until such date for its response.  The extension will enable the Company to more fully review and respond to the issues presented in the Comment Letter with its key personnel and external auditors.

If you have any questions regarding the foregoing, please contact Alec Tracy in Skadden Arps’ Hong Kong office at +852 3740 4710.  You may also contact Skadden Arps’ D.C. Office at (202) 371 7000 and ask to be transferred.

Sincerely,

/s/ Alec P. Tracy                                           

Alec P. Tracy

cc:        Ms. Kathleen Collins

Accounting Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

Arthur M. Wang

Chief Executive Officer

GigaMedia Limited

Quincy Tang

Chief Financial Officer

GigaMedia Limited

Thomas Hui

Chief Operating Officer

GigaMedia Limited

Lester Wong

General Counsel

GigaMedia Limited