United States securities and exchange commission logo
June 12, 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
Form 10-Q for the
quarterly period ended December 31, 2022
Response dated June
9, 2023
File No. 000-00121
Dear Lester Wong:
We have reviewed your June 9, 2023 response to our comment letter
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. Unless we note otherwise, our references to prior comments are
to comments in our
April 25, 2023 letter.
Form 10-K for the Fiscal Year Ended October 1, 2022
Notes to Consolidated Financial Statements
Note 16: Segment Information, page 68, page 68
1. We have reviewed your
response to comment 1 and have the following comments:
We note that you
currently believe your Aftermarket Product and Services ("APS")
reportable segment
consists of a single operating segment instead of six operating
segments and that
your Capital Equipment reportable segment consists of five
operating segments
instead of six operating segments. Considering you previously
indicated in
response to comment 2 in your letter dated April 12, 2023 that discrete
financial
information for each operating segment "is available to the CODM for his
Lester Wong
Kulicke and Soffa Industries, Inc.
June 12, 2023
Page 2
review during various updates throughout the financial year,
including revenue
outlooks, financial forecasts, business reviews and reports on
operations" and that
such "information is regularly reviewed by the CODM to make
decisions about
resources to be allocated to the component and assess its
performance," we are
unclear why you now believe APS consists of a single operating
segment and
why you no longer consider Wafer Level Bonder to be an operating
segment. In
doing so, clarify why the Wafer Level Bonder operating segment
was collapsed into
the Ball Bonder operating segment.
We note that the "Executive Summary Review" includes business
unit performance
measures for the six historical APS operating segments, including
gross margin and
direct operating margin. Please confirm whether or not your CODM
receives and
reviews this monthly package and tell us how he uses such
information.
Explain in greater detail how you determined your Ball Bonder
and Wedge Bonder
operating segments have similar economic characteristics. In
particular, address the
differences in operating margin percentage during fiscal years
2021 and 2022 and
how those variances compare to those in fiscal years 2018 and
2019.
Tell us if you believe the proposed revisions to your operating
segments represent an
error under ASC 250.
Explain how the proposed revisions to your operating segments
impacted your
assessments of the effectiveness of your internal controls over
financial reporting and
disclosure controls and procedures.
Tell us in sufficient detail how the proposed changes to your
operating segments
impact the composition of your reporting units for goodwill
impairment testing
purposes. If the reporting units would have differed for
historical periods, tell us how
your historical goodwill impairment tests would have been
impacted.
You may contact Beverly Singleton at (202) 551-3328 or Andrew Blume at
(202) 551-
3254 with any other questions.
FirstName LastNameLester Wong Sincerely,
Comapany NameKulicke and Soffa Industries, Inc.
Division of
Corporation Finance
June 12, 2023 Page 2 Office of
Manufacturing
FirstName LastName