Mail Stop 6010


	January 23, 2006


CT Corporation System
Agent for Service for
  Chip MOS Technologies (Bermuda) Ltd.
111 Eighth Avenue
New York, New York 10011

Re:	Chip MOS Technologies (Bermuda) Ltd.
	Amendment No. 1 to Registration Statement on Form F-3
      Filed January 10, 2006
      File No. 333-130230

Ladies and Gentlemen:

      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document in response to these comments.  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.

Selling Shareholders, page 135

1. Regarding your response to previous comment 1, please note that
Rule 430B(b) in general permits you only to omit information that
is
unknown or not reasonably available, the identities of selling
security holders and the amounts of securities registered on their
behalf.  Other information required by the form must be disclosed.
Therefore:

* Please disclose the aggregate number of securities being offered
by
the selling shareholders.

* Please expand your disclosure regarding the initial transaction
in
which the securities were sold to clarify when the selling
security
holders paid for the securities in full.


* Please expand your Plan of Distribution discussion to disclose
the
ways in which the selling security holders might sell the
securities.
This Plan of Distribution disclosure then can be amended in the
future as appropriate


*  *  *  *  *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      Please contact Donald C. Hunt at (202) 551-3647 or me at
(202)
551-3617 with any questions.

Sincerely,



	Russell Mancuso
	Branch Chief

cc (via fax):	Michael G. DeSombre, Esq.
	Sullivan & Cromwell LLP
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Chip MOS Technologies (Bermuda) Ltd.
January 23, 2006
Page 1