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United States securities and exchange commission logo
August 25, 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 August 14, 2020 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
July 9, 2020 letter.
Form 6-K Furnished July 30, 2020
Exhibit 99.1, page 8
1. We note from your
response to our prior comment 3 that you will change your
presentation in future
filings to present your non-GAAP measures "without appearing to
be a full non-GAAP
income statement." However, we note that your presentation did not
change from your Q1
2020 results furnished on April 29, 2020 to your Q2 2020 results
furnished on July 30,
2020, after the date of our letter on July 9, 2020. In this regard,
please provide us with
your proposed disclosure in future Forms 6-K.
2. We note your response
to our prior comment 4 that you will "discontinue the presentation
of FCI divestiture
adjustments in subsequent periods when for sequential or year-after-
year comparisons, past
periods no longer include FCI operating results and the gain from
divestiture." However,
we continue to believe that as the FCI divested operations did not
Riyadh Lai
Silicon Motion Technology Corporation
August 25, 2020
Page 2
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. Therefore, as originally
stated, please revise
your non-GAAP presentations to comply with Question 100.04 of the
Non-GAAP C&DIs
by removing the FCI divestiture adjustments. Please be advised that
the revenue example
discussed in Question 100.04 is only one example of a tailored
measure. Note that
alternatively, you may adjust for just the gain from the divestiture,
given that it was a one-
time, non-cash charge.
You may contact Heather Clark at 202-551-3624 or Melissa Raminpour at
202-551-
3379 with any questions.
FirstName LastNameRiyadh Lai Sincerely,
Comapany NameSilicon Motion Technology Corporation
Division of
Corporation Finance
August 25, 2020 Page 2 Office of
Manufacturing
FirstName LastName