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We note the significance of the benefit from foreign income taxed at other than U.S. rates as disclosed in the income tax rate reconciliation on page 75. We also note the significant difference between the U.S. statutory rate and your foreign effective tax rate. In light of the significant impact of lower taxes on foreign earnings to your operating results, in future filings please explain the relationship between foreign pre-tax income and the foreign effective tax rate in greater detail. In that regard, please disclose the foreign effective tax rate, with accompanying description of the primary jurisdictions where your foreign income is earned for tax purposes and the statutory rates and incentives in those jurisdictions. It appears that separately discussing the foreign effective income tax rate is important information material to an understanding of your results of operations. Refer to Item 303(a)(3)(i) of Regulation S-K and Section III.B of SEC Release 33-8350.

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1.	You disclose that you have one reportable segment based on an aggregation of five operating segments. Please tell us and in future filings disclose how you have applied the guidance from FASB ASC 280-10-50-11 in concluding that it is appropriate to aggregate the five operating segments for financial statement purposes.

•	Nature of product and services: The primary source of revenue for each operating segment is the sale of ICs. The Company's revenues for all operating segments have similar degrees of risk, including rapid technological changes, competitive pricing

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Nature of production processes: The ICs sold by each of the Company's operating segments are manufactured using similar raw materials and semiconductor manufacturing processes which are conducted in either the Company’s own production facilities or by third-party wafer fabricators. Raw materials used to manufacture these devices include silicon wafers, processing chemicals, precious metals and ceramic and plastic used for packaging. Semiconductor production steps include wafer fabrication, wafer testing, cutting the wafer into individual “chips,” or dice, assembly of the dice into packages and electrical testing of devices in final packaged form. The Company does not segregate its manufacturing production lines by operating segment. All of the Company's manufacturing facilities, including equipment, composition of employees, and materials and tools required for production are similar for each operating segment.

•	The type or class of customer for products and services: The Company sells its products to tens of thousands of customers worldwide. Many of these customers use products spanning all our operating segments in a wide range of applications.

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The methods used to distribute products: The ICs marketed by each of the Company's operating segments are sold globally through a direct sales force, third-party distributors and independent sales representatives and via our website to the same types of customers. The Company does not segregate product distribution by operating segment, and many of our distributors and sales representatives market and sell products from all of our operating segments. Our sales employees act as a pool of resources to support all of our operating segments. Sales strategies are consistent across regions, geographies and operating segments.

◦	The primary source of revenue for each operating segment is the sale of integrated circuits.

◦	The integrated circuits sold by each of the Company's operating segments are manufactured using similar semiconductor manufacturing processes and raw

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◦	The Company sells its products to tens of thousands of customers worldwide. Many of these customers use products spanning all operating segments in a wide range of applications.

◦	The integrated circuits marketed by each of the Company's operating segments are sold globally through a direct sales force, third-party distributors and independent sales representatives and via our website to the same types of customers.

•	the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•	staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

•	the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.