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Published on May 23, 2008
[Letterhead
of Wilson Sonsini Goodrich & Rosati]
May 23,
2008
Via
EDGAR
Securities
and Exchange Commission
Division
of Corporate Finance
100 F
Street, N.E.
Washington,
DC 20549
Attention: Kevin
Kuhar, Division of Corporate Finance
|
|
Re:
|
Microchip
Technology Incorporated
|
Form 10-K for fiscal year ended March
31, 2007
Commission File No.
0-21184
Ladies
and Gentlemen:
On behalf
of Microchip Technology Incorporated (the “Company”), we are responding to a
verbal comment discussed on or about May 8, 2008 with Kevin Kuhar of the Staff
(the “Staff”) of the Securities and Exchange Commission regarding the Company’s
response to comment number 4 in the Staff’s letter dated March 25, 2008 relating
to the Company’s Form 10-K for the fiscal year ended March 31,
2007.
As
conveyed in telephone messages with the Staff, this letter is to confirm that in
future filings the Company will include disclosure regarding its gross deferred
revenue, gross deferred cost of sales and deferred income on shipments to
distributors as part of the disclosure of its revenue recognition policy in its
Management’s Discussion and Analysis of Financial Condition and Results of
Operations.
If you
should have any questions regarding the Company’s response, please do not
hesitate to contact the undersigned at (512) 338-5400.
Very
truly yours,
WILSON
SONSINI GOODRICH & ROSATI
Professional
Corporation
/s/ J.
Robert Suffoletta
J. Robert
Suffoletta, Esq.
Enclosure