February 28, 2020

Lester Wong
Chief Financial Officer
Kulicke & Soffa Industries, Inc.
23A Serangoon North Avenue 5 #01-01
Singapore 554369

       Re: Kulicke and Soffa Industries, Inc.
           Form 10-K for the Fiscal Year Ended September 28, 2019
           Filed November 15, 2019
           File No. 000-00121

Dear Mr. Wong:

       We have reviewed your filing 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-K for the Fiscal Year Ended September 28, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 24

1.    We note that your results of operations section in MD&A discusses the
changes in
      revenue and gross profit by segment. However, we note from your
disclosure in Note 14
      that segment operating income is the measure used by your chief operating
decision maker
      in deciding how to allocate resources and assess performance. We also
note that although
      the Capital Equipment segment generated the larger revenue and gross
profit amounts of
      the two segments in fiscal 2019, it generated a loss from operations,
while APS had
      income from operations. In light of this disproportionate contribution of
the Capital
      Equipment segment to operating income relative to its contribution to
revenue, it
      appears that investors would benefit from a discussion of segment
operating income in
      your results of operations discussion within MD&A. Please consider
revising as
      appropriate.
 Lester Wong
FirstName Soffa Industries, Inc.
Kulicke & LastNameLester Wong
Comapany NameKulicke & Soffa Industries, Inc.
February 28, 2020
Page 2
February 28, 2020 Page 2
FirstName LastName




Notes to Consolidated Financial Statements
Note 3: Goodwill and Intangible Assets
Goodwill, page 47

2.       We note your disclosure that you performed your annual assessment in
the fourth quarter
         of fiscal 2019 and concluded that no impairment charge was required
and that during
         fiscal year 2019 and through the three months ended December 28, 2019,
you reviewed
         qualitative factors and determined that no triggering event had
occurred to indicate that
         the fair value of the reporting unit is below its carrying value. We
further note that net
         revenues for your capital equipment segment in fiscal 2019 decreased
46.2% from fiscal
         2018 and decreased 11.7% for the three months ended December 28, 2019
compared to
         the same period for 2018, and the segment had a loss from operations
in fiscal 2019 of
         $12.5 million. Please tell us how you considered the factors pursuant
to ASC 350-20-35-3
         in determining that further impairment testing was not necessary given
the decreases in
         net revenues and gross profit for your capital equipment segment.
Additionally, please
         tell us if the fair values of each of your reporting units are
substantially in excess of their
         carrying values.
Note 10. Revenue and Contract Liabilities, page 57

3.       We note from your disclosure in Note 10 that you report revenue based
on your reportable
         segments and you believe that reporting revenue on this basis provides
information about
         how the nature, amount, timing, and uncertainty of revenue and cash
flows are affected by
         economic factors. However, we note that in your investor presentations
and earnings calls,
         you discuss the business in terms of certain end markets such as
automotive, advanced
         packaging, and memory, among others, as well as product categories
such as your wire
         bonder business and ball bonder business. Additionally, we note that
each of your two
         reportable segments consists of six operating segments. In light of
this, it appears it may
         be appropriate to disclose revenue on a further disaggregated basis.
Please tell us how
         you considered the guidance in ASC 606-10-55-90 through 55-91 when
determining the
         appropriate level of disaggregation of revenue.
 Lester Wong
Kulicke & Soffa Industries, Inc.
February 28, 2020
Page 3




        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 Melissa Gilmore at (202) 551-3777 or Claire Erlanger at
(202) 551-
3301 if you have any questions.



FirstName LastNameLester Wong                             Sincerely,
Comapany NameKulicke & Soffa Industries, Inc.
                                                          Division of
Corporation Finance
February 28, 2020 Page 3                                  Office of
Manufacturing
FirstName LastName