SEC Comment Letter for SMTC CORP (CIK 0001108320) — Jan 29, 2021
SMTC CORP (CIK 0001108320)
Date: Jan. 29, 2021 · CIK: 0001108320 · Accession: 0000000000-21-001153
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File numbers found in text: 000-31051
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United States securities and exchange commission logo
January 29, 2021
Edward Smith
President, Chief Executive Officer and Director
SMTC CORP
7050 Woodbine Avenue
Markham, Ontario
Canada L3R 4G8
Re:SMTC CORP
Preliminary Proxy Statement on Schedule 14A
Filed January 21, 2021
File No. 000-31051
Dear Mr. Smith:
We have reviewed your filing 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.
Preliminary Proxy Statement on Schedule 14A filed on January 21, 2021
General
1.Please provide us you analysis of the applicability of Exchange Act Rule 13e-3 to the
transaction referenced in your disclosure. Please cite all authority on which you rely.
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 LastNameEdward Smith
Comapany NameSMTC CORP
January 29, 2021 Page 2
FirstName LastName
Edward Smith
SMTC CORP
January 29, 2021
Page 2
Please contact Geoff Kruczek at (202) 551-3641 or Jay Ingram, Legal Branch Chief, at
(202) 551-3397 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Chris Hall