KULICKE & SOFFA INDUSTRIES INC (KLIC) – Company response

Company response: The Company acknowledges the Staff’s comment. The negative selling, general and administrative (“SG&A”) amount for the Advanced Solutions segment for the three months ended December 28, 2024 primarily reflects income recognized during that period, including gains and reimbursements associated with the cessation of business as a result of the cancellation of a prior project, previously referred to as Project W (the "Project"). This was previously disclosed in Note 17: Cessation of Business in the Company's Annual Report on Form 10-K for the fiscal year ended October 4, 2025. In response to the Staff’s comment, the Company will revise its future filings to include an explanatory note to the… response letter →

Company response: The Company considered the requirements of Item 303(b) of Regulation S-K in preparing its MD&A for the quarterly period ended January 3, 2026, including whether to separately discuss changes in segment income from operations, which is the primary segment profitability measure reviewed by the Chief Operating Decision Maker (“CODM”) and disclosed in Note 15 to the consolidated condensed financial statements. As disclosed in Note 15, the CODM evaluates performance and allocates resources primarily based on income from operations, and the CODM is regularly provided with segment-level revenue, cost of sales, selling, general and administrative (“SG&A”) expense, and research and development… response letter →

Company response: The Company acknowledges the Staff’s comment and the guidance in Item 303(b) of Regulation S-K. In preparing the MD&A, the Company identified multiple factors contributing to period-to-period changes in net revenue and other income statement line items, including changes in volume, product and customer mix, pricing, and other factors. In response to the Staff’s comment, the Company will revise its future filings to quantify, where possible, the impact of each material contributing factor, including any offsetting factors, in dollars and/or percentages, and to expand its discussion of the underlying reasons driving these changes. The Company will apply this enhanced level of quantification… response letter →