Mail Stop 6010


August 18, 2005



Shih-Jye Cheng, Chairman and Chief Executive Officer
ChipMOS Technologies (Bermuda) Ltd.
No. 1,  R & D Road 1
Hsinchu Science Park
Hsinchu, Taiwan
Republic of China



	Re:	ChipMOS Technologies (Bermuda) Ltd.
		Form 20-F for the fiscal year ended December 31, 2004
		Forms 6-K for fiscal 2005
		File No.  0-31106

Dear Mr. Cheng:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures, and do not intend to expand our review to
other
portions of your documents. Where indicated, we think you should
revise your documents in response to these comments in all future
filings with the Commission.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.



Mr. Shih-Jye Cheng
ChipMOS Technologies (Bermuda) Ltd.
August 18, 2005
Page 2


Form 20-F for the year ended December 31, 2004


Audited Financial Statements, beginning on page F-1

Summary of Significant Differences Between Accounting Principles
Followed by the Company and Accounting Principals Generally
Accepted
in the United States, page F-41

1. We see that you consolidate Modern Mind and its subsidiary and
ThaiLin Semiconductor. We also see that you own no shares in
Modern
Mind and hold a 27.6% interest in ThaiLin Semiconductor.  For US
GAAP
purposes please explain why it is appropriate to consolidate these
entities.  Identify and describe the basis in GAAP and explain how
you applied the literature to your fact pattern.

2. As a related matter, if you have consolidated Modern Mind and
its
subsidiary and ThaiLin Semiconductor in reliance on FIN 46, show
us
that your financial statements present all of the relevant
disclosures required by that guidance.

3. We see that you recognize revenue at shipment and that shipment
also includes shipment to your warehouse for customers using your
warehousing services.  Accordingly, it appears that you recognize
revenue on a bill and hold basis.  For US GAAP purposes, provide
us
an analysis demonstrating that your revenue policy for shipments
to
your internal warehouse is appropriate.  Show us that you have
appropriately applied the guidance from SAB Topic 13 for bill and
hold arrangements.

4. We see that recoveries of the allowance for inventories are
reported as income for ROC GAAP purposes.  For US GAAP purposes,
inventory reserves or allowances are not reversed until the
affected
inventory is disposed.  Tell us how your method is faithful to the
requirements of SAB Topic 5-BB.  Future filings should present
disclosure about any US/ROC GAAP difference for this matter.

5. In Note 28(b) we see an unrealized loss on equity securities
totaling approximately $7 million. The disclosure suggests that
the
securities have been impaired for more than twelve months.  For US
GAAP purposes tell us why there is no other than temporary
impairment.  Please provide a full explanation of the basis for
your
conclusions.  Also fully describe how you considered the
requirements
of US GAAP for this matter.



Mr. Shih-Jye Cheng
ChipMOS Technologies (Bermuda) Ltd.
August 18, 2005
Page 3


6. We see disclosure in the last paragraph on page 78 about an $8
million unrealized loss associated with an investment in Ultima
Technology.  For US GAAP purposes, tell us why that unrealized
loss
is not other than temporary.

7. Under Note 28(c) please expand future filings to also disclose
pre-tax accounting income from domestic and foreign sources.
Refer
to S-X Rule 4-08(h).

8. In future filings please expand Note 28(d) to more fully comply
with the requirements of SFAS 132(R).  For instance, please make
disclosure about plan assets under paragraph 5(d) and, if
applicable,
5(n).

9. In Notes 28(e) and (f) we see that the currency translation
adjustment is the same amount as the effect of changes in foreign
exchange rates on cash and cash equivalents. For US GAAP purposes
under SFAS 95, those items are not similarly determined and should
not normally be the same amounts. Tell us how your cash flow
statement and the calculation of the impact of exchange rates on
cash
considers the guidance from Example 2 to Appendix C to SFAS 95.
Advise and revise future filings as necessary.

10. We see that ChipMOS Bermuda issued convertible bonds totaling
$85
million in 2004.  Tell us how your accounting for those bonds
considers the requirements of EITF 98-5.  Future filings should
disclose the terms of conversion.




      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a response letter that keys your responses to our
comments and provides the requested information.  Confirm that you
will comply with these comments in all future filings with the
Commission.  Detailed response letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your responses to our comments and the requested
information.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that the filing includes all information required under
the
Securities Exchange Act of 1934 and that they have provided all
information investors require for an informed decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.


Mr. Shih-Jye Cheng
ChipMOS Technologies (Bermuda) Ltd.
August 18, 2005
Page 4


	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* 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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.


      You may contact Jeanne Bennett at (202) 551-3606, or me at
(202) 551-3605, if you have questions regarding our comments.  In
our
absence you may contact Brian R. Cascio, Accounting Branch Chief,
at
(202) 551-3676

      Sincerely,


      Gary R. Todd
								Reviewing Accountant



Copy to:	Sami Farhad, Esq.
		Sullivan & Cromwell in Hong Kong
		(852) 2522-2280

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