United States securities and exchange commission logo





                              March 14, 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
                                                            Filed November 17,
2022
                                                            Form 10-Q for the
quarterly period ended December 31, 2022
                                                            Filed February 2,
2023
                                                            File No. 000-00121

       Dear Lester Wong:

              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-K for the Fiscal Year Ended October 1, 2022

       Notes to Consolidated Financial Statements
       Note 15: Income Taxes, page 65

   1.                                                   We note that the
majority of your pre-tax income is derived from foreign sources. Please
                                                        disclose in future
filings the amount of unremitted foreign earnings and the unrecognized
                                                        deferred tax liability
on unremitted foreign earnings or a statement that such determination
                                                        is not practicable. See
ASC 740-30-50-2b and 2c.
       Note 16: Segment Information, page 68

   2.                                                   We note the disclosure
on page 23 of your Form 10-Q for the period ended December 31,
                                                        2022 that your Capital
Equipment and Aftermarket Products and Services reportable
 Lester Wong
FirstName
Kulicke andLastNameLester
             Soffa Industries,Wong
                               Inc.
Comapany
March      NameKulicke and Soffa Industries, Inc.
       14, 2023
March2 14, 2023 Page 2
Page
FirstName LastName
         segments both consist of six aggregated operating segments. Please
identify for us your
         operating segments and tell us in sufficient detail how you determined
your operating
         segments meet all aggregation criteria described in ASC 280-10-50-11.
In particular,
         explain how you determined all operating segments have similar
economic
         characteristics. We note from your first quarter 2023 earnings call
that management
         primarily discusses results and trends of your various "markets," such
as automotive and
         industrial, wire bonding, wedge bonding, LED, and memory, with minimal
discussion of
         your overall reportable segments. We further note from your
disaggregated revenue
         disclosures on page 68 of your Form 10-K and page 20 of your most
recent Form 10-Q
         that certain end markets appeared to have disparate revenue trends for
the annual and
         interim periods presented.
Form 10-Q for the Quarterly Period Ended December 31, 2022

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 26

3.       Please provide a more informative analysis and discussion of your
results of operations in
         future filings. We note, for example, that you attribute the
approximate 92% decline in
         your income from operations for the year-over-year interim periods "to
lower revenues as
         explained...above." Further, you ascribe the approximate 62% decline
in interim net
         revenues to lower volumes caused by "a decrease in customer
investments as a result of
         uncertainties in the overall macroeconomic environment" and "a
decrease in customer
         utilization." Enhance these overly broad and generic descriptions to
provide a frame of
         reference that allows readers to understand the effects of material
changes and events and
         known material trends and uncertainties arising during the periods
being discussed, as
         well as their relative importance. Ensure that your revised
disclosures assist in satisfying
         the three principal objectives of MD&A, as noted in SEC Release No.
33-8350:

                to provide a narrative explanation of a company   s financial
statements that enables
              investors to see the company through the eyes of management;

                to enhance the overall financial disclosure and provide the
context within which
              financial information should be analyzed; and

                to provide information about the quality of, and potential
variability of, a company   s
              earnings and cash flow, so that investors can ascertain the
likelihood that past
              performance is indicative of future performance.



       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.
 Lester Wong
Kulicke and Soffa Industries, Inc.
March 14, 2023
Page 3

      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
March 14, 2023 Page 3                                  Office of Manufacturing
FirstName LastName