United States securities and exchange commission logo





                               February 2, 2021

       Dean Bulter
       Chief Financial Officer
       Synaptics Inc
       1251 McKay Drive
       San Jose, CA 95131

                                                        Re: Synaptics Inc
                                                            Form 10-K for the
Fiscal Year Ended June 27, 2020
                                                            Filed on August 21,
2020
                                                            File No. 000-49602

       Dear Mr. Bulter:

              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 June 27, 2020

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 39

   1.                                                   Where you describe two
or more business reasons that contributed to a material change in
                                                        a financial statement
line item between periods, please quantify in future filings, where
                                                        possible, the extent to
which each change contributed to the overall change in that line
                                                        item. In addition,
where you identify intermediate causes of changes in your operating
                                                        results, also describe
the reasons underlying the intermediate causes. For example, you
                                                        disclose that net
revenue was impacted by changes in units sold and average selling
                                                        prices. Please quantify
the extent to which the overall change in revenues is attributable
                                                        to each identified
factor and explain in reasonable detail the reasons driving fluctuations in
                                                        each factor. Ensure
that your revised disclosures assist in satisfying the requirements of
                                                        Item 303(a) of
Regulation S-K and the three principal objectives of MD&A, as noted in
                                                        SEC Release No.
33-8350:
 Dean Bulter
FirstName  LastNameDean Bulter
Synaptics Inc
Comapany2,NameSynaptics
February    2021        Inc
February
Page 2 2, 2021 Page 2
FirstName LastName

                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
Notes to Consolidated Financial Statements
4. Divestiture, page F-17

2.       We note that you divested your TDDI product line in April 2020. Based
on the pro forma
         financial statements provided in your Form 8-K filed April 16, 2020,
it appears that TDDI
         was quantitatively material to your statements of operations,
including revenues and
         operating, pre-tax, and net income. Please tell us how you determined
TDDI did not meet
         the criteria to qualify as discontinued operations under ASC
205-20-45-1B.
12. Segment, Customers, and Geographic Information, page F-33

3.       Although you disclose you have a single reportable segment, we note
that management
         refers to your product lines during earnings calls as "businesses" and
that the management
         team on your website includes Senior Vice President and General
Manager positions for
         the PC & Peripherals, Wireless Connectivity, Multimedia, and Smart
Sensing and Display
         Divisions. Please tell us in sufficient detail how you determined that
you have only one
         reportable segment. In doing so, tell us each operating segment you
have identified under
         ASC 280-10-50-1 and provide us with the following information:

                Tell us the title and describe the role of the Chief Operating
Decision Maker
              ("CODM") and each of the individuals that report to the CODM;

                Identify and describe the role of each segment manager;

                Tell us how often the CODM meets with his/her direct reports,
the financial
              information the CODM reviews to prepare for those meetings, the
financial
              information discussed in those meetings, and who else attends
those meetings;

                Describe the information regularly provided to both the CODM
and the Board of
              Directors, and how frequently it is prepared; and

                Explain to us the responsibilities of each Senior Vice
President and General Manager
              identified above, including to whom they report and how they are
compensated.

         We remind you that the company and its management are responsible for
the accuracy
 Dean Bulter
Synaptics Inc
February 2, 2021
Page 3

and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Jean Yu at 202-551-3305 or Andrew Blume at 202-551-3254
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Sherry Haywood at 202-551-3345 or Jay Ingram at 202-551-3397 with any
other
questions.



FirstName LastNameDean Bulter                             Sincerely,
Comapany NameSynaptics Inc
                                                          Division of
Corporation Finance
February 2, 2021 Page 3                                   Office of
Manufacturing
FirstName LastName