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United States securities and exchange commission logo
July 9, 2020
Riyadh Lai
Chief Financial Officer
Silicon Motion Technology Corporation
690 N. McCarthy Blvd, Suite 200
Milpitas, California 95035
Re: Silicon Motion
Technology Corporation
Form 20-F for the
Year Ended December 31, 2019
Form 6-K furnished
April 29, 2020
File No. 000-51380
Dear Mr. Lai:
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 20-F for the Year Ended December 31, 2019
Item 5. Operating and Financial Review and Prospects
Results of Operations, page 32
1. In your discussion of
changes in your results operations, you quantify factors contributing
to the changes in
revenues and expenses from year to year for some of your financial
statement line items.
However, you do not appear to include the underlying reasons for
the changes. We also
note that you do not explain the change in line items such as
amortization of
intangible assets, interest income, interest expense, foreign exchange gain
(loss), and income tax
expense (benefit). Please expand your disclosures to provide the
business reasons for
material changes in your operating results between reporting periods.
In circumstances where
more than one business reason exists for a change between
periods, please also
quantify the incremental impact of each individual business reason.
Refer to Part I, Items
5(A) and 5(D) of Form 20-F and Section III.B.4 of SEC Release 33-
8350. Please provide us
with your proposed disclosure in your response.
Riyadh Lai
Silicon Motion Technology Corporation
July 9, 2020
Page 2
Financial Statements
Notes to Consolidated Financial Statements
Note 15. Income Taxes, page F-27
2. Please explain the decreasing nature of the line item differences
between Cayman and
foreign statutory tax rates" from 2017 to 2019.
Form 6-K furnished April 29, 2020
Exhibit 99.1, page 9
3. We note that you present what appears to be a full non-GAAP income
statement when
reconciling non-GAAP measures to the most directly comparable GAAP
measures.
Please revise your presentation to eliminate the presentation of a
full non-GAAP income
statement in your next earnings release. Refer to the guidance in
Question 102.10 of the
Compliance and Disclosure Interpretations Regarding Non-GAAP Measures.
4. Additionally, we note your non-GAAP adjustments related to your FCI
divestiture. As
these divested operations did not meet the criteria for being
presented as discontinued
operations pursuant to ASC 205-20, your non-GAAP measures appear to
substitute
individually tailored recognition and measurement methods for those of
GAAP. In future
filings, please revise your non-GAAP presentations to comply with
Question 100.04 of
the Non-GAAP C&DIs by removing the FCI divestiture adjustments.
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.
You may contact Heather Clark, Staff Accountant, at 202-551-3624 or
Melissa
Raminpour, Accounting Branch Chief, at 202-551-3379 with any questions.
FirstName LastNameRiyadh Lai Sincerely,
Comapany NameSilicon Motion Technology Corporation
Division of
Corporation Finance
July 9, 2020 Page 2 Office of
Manufacturing
FirstName LastName