SEC Comment Letter for IMAX CORP (IMAX) (CIK 0000921582) (IMAX) — Mar 19, 2020
IMAX CORP (IMAX) (CIK 0000921582)
Date: March 19, 2020 · CIK: 0000921582 · Accession: 0000000000-20-002446
AI Filing Summary & Sentiment
File numbers found in text: 001-35066
Letter
March 19, 2020 Patrick McClymont Chief Financial Officer IMAX CORP 2525 Speakman Drive Mississauga, Ontario, Canada L5K 1B1 Re:IMAX CORP Form 10-K for the year ended December 31, 2019 Filed on February 19, 2020 File No. 001-35066 Dear Mr. McClymont: 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 Fiscal Year Ended December 31, 2019 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Discussion for the Two Years Ended December 31, 2019, page 53 1.We note that you have relied upon Instruction 1 to Item 303(a) of Regulation S-K to omit a discussion of the earliest of the three years and included a statement that identifies the location of such discussion in a prior filing. However, your disclosure does not expressly state that the information is incorporated by reference as required by Exchange Act Rule 12b-23(e). Refer to Question 110.02 of the Regulation S-K Compliance & Disclosure Interpretations updated January 24, 2020, and revise future filings to properly incorporate the discussion by reference. 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.
FirstName LastNamePatrick McClymont Comapany NameIMAX CORP March 19, 2020 Page 2 FirstName LastName Patrick McClymont IMAX CORP March 19, 2020 Page 2 You may contact Ameen Hamady at 202-551-3891 or in his absence, Tracie Mariner at 202-551-3744 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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March 19, 2020
Patrick McClymont
Chief Financial Officer
IMAX CORP
2525 Speakman Drive
Mississauga, Ontario, Canada L5K 1B1
Re:IMAX CORP
Form 10-K for the year ended December 31, 2019
Filed on February 19, 2020
File No. 001-35066
Dear Mr. McClymont:
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 Fiscal Year Ended December 31, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations Discussion for the Two Years Ended December 31, 2019, page 53
1.We note that you have relied upon Instruction 1 to Item 303(a) of Regulation S-K to omit
a discussion of the earliest of the three years and included a statement that identifies the
location of such discussion in a prior filing. However, your disclosure does not expressly
state that the information is incorporated by reference as required by Exchange Act Rule
12b-23(e). Refer to Question 110.02 of the Regulation S-K Compliance & Disclosure
Interpretations updated January 24, 2020, and revise future filings to properly incorporate
the discussion by reference.
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.
FirstName LastNamePatrick McClymont
Comapany NameIMAX CORP
March 19, 2020 Page 2
FirstName LastName
Patrick McClymont
IMAX CORP
March 19, 2020
Page 2
You may contact Ameen Hamady at 202-551-3891 or in his absence, Tracie Mariner at
202-551-3744 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences