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United States securities and exchange commission logo
June 30, 2021
Brett R. Whitmire
Chief Financial Officer
DIODES INCORPORATED
4949 Hedgcoxe Road, Suite 200
Plano, Texas 75024
Re: DIODES INCORPORATED
Form 10-K for the
Year Ended December 31, 2020
Filed February 22,
2021
Form 10-Q for the
Period Ended March 31, 2021
Filed May 6, 2021
File No. 002-25577
Dear Mr. Whitmire:
We have limited our review of your filing to the financial
statements and related
disclosures 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 10-K for the Year Ended December 31, 2020
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations, page 39
1. In your earnings call
for the fourth quarter of 2020, you provided detailed discussions on
sales by end market.
With a view towards future disclosure, please tell us what
consideration you gave
to providing similar disclosures in your annual and quarterly
reports since they
provide insight into how management views the business.
Brett R. Whitmire
FirstName LastNameBrett R. Whitmire
DIODES INCORPORATED
Comapany
June NameDIODES INCORPORATED
30, 2021
June 30,
Page 2 2021 Page 2
FirstName LastName
Form 10-Q for the Period Ended March 31, 2021
Management's Discussion and Analysis of Financial Condidtion and Results of
Operations
Results of Operations, page 23
2. We note your disclosures that the increase in net sales during the
current interim period
was driven by growth in certain regions and end markets. We also note
your disclosure
that this is the first full quarter of revenue from the LSC
acquisition. Please revise your
disclosures related to changes in net sales to quantify and more fully
explain the reasons
for changes in net sales during each period presented. For example,
please quantify the
impact of sales related to the LSC acquisition and better explain the
underlying reasons
for sales growth in certain regions and end markets.
In closing, 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 SiSi Cheng at 202-551-5004 or Anne McConnell at
202-551-3709 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing