October 14, 2010
VIA EDGAR AND FACSIMILE
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3030
100 F Street, NE
Washington, D.C. 20549
| Attention: | Kevin L. Vaughn, Accounting Branch Chief |
Martin James, Senior Assistant Chief Accountant
Tara Harkins, Staff Accountant
Division of Corporation Finance
| RE: | Verigy Ltd. |
Form 10-K for the Year Ended October 31, 2009
File No. 000-52038
Ladies and Gentlemen:
As a supplement to our response dated September 29, 2010, we wish to inform you that we have now completed our annual assessment to determine whether our operating segments exhibit similar characteristics and, as a result, confirm that we will disclose our two operating segments separately as two reportable segments in our Form 10-K for our fiscal year ended October 31, 2010 and, in accordance with ASC 280-10-50-34, prior period segment data presented for comparative purposes will be revised to present the memory and SOC segments as separate reportable segments.
* * *
Securities and Exchange Commission
Re: Verigy Ltd.
October 14, 2010
Page 2
Please feel free to contact me directly at (408) 864-7531, or Margo Smith, Vice President and General Counsel, at (408) 864-7515 with any further comments or questions that you may have. The Company respectfully requests that the Staff confirm that it has no additional requests or comments on the Form 10-K when the Staff’s review is complete.
| Very truly yours, |
| /s/ Robert J. Nikl |
Robert J. Nikl Chief Financial Officer |
| cc: | Margo M. Smith, Verigy Ltd., Vice President and General Counsel |
