[November 15, 2010 VIA FACSIMILE AND EDGAR Ms. Kathleen Collins Accounting Branch Chief Division of Corporation Finance One Station Place 100 F Street N.E. Re: GigaMedia Limited Form 20-F for the Fiscal Year Ended December 31, 2009 Filed June 30, 2010 File No. 0-30540 Dear Ms. Collins: Form 20-F for the Fiscal Year Ended December 31, 2009 Item 3. Key]

[November 5, 2010 VIA FACSMILE AND EDGAR Ms. Barbara Jacobs Assistant Director Division of Corporation Finance 100 F Street, N.E. RE: GigaMedia Limited (File no. 0-30540) Form 20-F for the Fiscal Year Ended December 31, 2009 Filed June 30, 2010 Request for Extension to Comment Letter Response Dear Ms. Jacobs: I refer to our telephone call on November 5, 2010.]

[November 2, 2010 VIA FACSMILE AND EDGAR Ms. Kathleen Collins Accounting Branch Chief Division of Corporation Finance 100 F Street, N.E. RE: GigaMedia Limited (File no. 0-30540) Form 20-F for the Fiscal Year Ended December 31, 2009 Filed June 30, 2010 Request for Extension to Comment Letter Response Dear Ms. Collins: If you have any questions regarding the foregoing, please]

[September 29, 2010 VIA FACSIMILE AND EDGAR Ms. Kathleen Collins Accounting Branch Chief Division of Corporation Finance One Station Place 100 F Street N.E. Re: GigaMedia Limited Form 20-F for the Fiscal Year Ended December 31, 2009 Filed June 30, 2010 File No. 0-30540 Dear Ms. Collins: Form 20-F for the Fiscal Year Ended December 31, 2009 Item 3. Key]