Sheppard, Mullin, Richter & Hampton LLP
379 Lytton Avenue
Palo Alto, California 94301
650.815.2600 main
650.815.2601 fax
www.sheppardmullin.com
Jason R. Schendel
650.815.2621 direct
jschendel@sheppardmullin.com
July 31, 2019
Via Federal Express
Division of Corporation Finance Office of Electronics and Machinery U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attention Julie Sherman and Martin James |
|
Re: | DIODES INC /DEL/ |
Filed February 21, 2019
Form 10-Q for the Quarterly Period Ended March 31, 2019
Filed May 7, 2019 |
File No. 002-25577
|
Dear Julie Sherman and Martin James:
This letter is being delivered in order to respond to the comments from the staff (the "Staff") of the Securities and Exchange Commission (the “Commission”) provided to Diodes Incorporated, a Delaware corporation (the “Company”), in a letter dated July 26, 2019 (the "Comment Letter") related to the Company’s most recent annual report on Form 10-K and quarterly report on Form 10-Q.
The Staff’s comments set forth in the above-mentioned Comment Letter are reproduced below in italics, followed by the Company's responses.
Form 10-Q for the Quarter ended March 31, 2019
Note 7 - Segment Information and Net Sales, page 13
1. | We note the increased focus on your end markets, namely industrial, consumer, communications, computing and automotive, in your discussion of revenues in MD&A as well as in your discussions during the 2019 first quarter earnings call. Please explain to us your conclusion not to provide comparative revenues by end markets as part of your enterprise-wide disclosures pursuant to the guidance in ASC 280-10-50-40, or confirm that you will provide the disclosures in future filings. |
July 31, 2019
Page 2
Response: The Company has discussed the Staff’s comments set forth in the Comment Letter with its management team and external advisors. Following such further consideration, the Company has determined to include comparative revenue measurements by end markets as part of its enterprise-wide disclosures pursuant to the guidance in ASC 280-10-50-40, as requested by the Staff. The first such disclosure will appear in the Company’s Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2019, which the Company will file with the Commission on or about August 5, 2019.
If you have any questions with respect to the foregoing, please do not hesitate to contact the undersigned (telephone: (650) 815-2621; email: jschendel@sheppardmullin.com) of Sheppard, Mullin, Richter & Hampton LLP, counsel to the Company.
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July 31, 2019
Page 3
Please indicate receipt of this letter by date stamping the enclosed copy of the first page of this letter and returning it to us in the prepaid, self-addressed envelope provided.
| Sincerely,
/s/ Jason R. Schendel
Jason R. Schendel | |
| for Sheppard, Mullin, Richter & Hampton llp | |
Enclosures
cc: | Brett R. Whitmire, Diodes Incorporated |
