SecProbe.io

September 2 8, 2012

Via E -mail
Mr. Sang Park
Chief Executive Officer  and Chairman of the Board of Directors
MagnaChip Semiconductor Corporation
c/o MagnaChip Semiconductor S.A.
74, rue de Merl,  B.P. 709, L -2146
Luxembourg  R.C.S.
Luxembourg  B97483

 Re: MagnaChip Semiconductor Corporation
  Form 10-K for the Fiscal Year Ended  December 31, 2011
Filed  March 8, 2012
  File No.  1-34791

Dear Mr.  Park:

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 this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provid e in response to these comments, we may
have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 20 11

Management Discussion and Analysis of Financial Condition and Results of Operations, page 45

Results of Operations, page 55

1. We not e you conduct significant operations outside your home country in functional
currencies that differ from your reporting currency.  Please tell us any material effects of
changes in currency exchange rates on reported revenues and costs as well as business
practices and plans.  Refer to Item 303(A)(3) of Regulation S -K and Financial Reporting
Codification 501.09.b.

Mr. Sang Park
MagnaChip Semiconductor Corporation
September 2 8, 2012
Page 2

Notes to Consolidated Financial Statements, page 92

Note 9. Inventories, page 106

2. Please explain to us the “change in reserve” of $2,997 in th e year ended December 31,
2011. Tell us how your accounting complies with SAT Topic 5.BB, which states that a
write -down of inventory to the lower of cost or market creates a new cost basis that
subsequently cannot be marked up based on changes in underlyi ng facts and
circumstances.

3. Further to the above, if material, please revise future filings to quantify how changes in
the inventory valuation allowances, including sales of previously written down inventory,
impact your gross margins.

Note 30 - Condensed Consolidated Financial Statements, page 130

4. We note your disclosure here that the guarantees are full and unconditional, subject to
certain customary release provisions. Please explain to us in greater detail the nature of
the customary release provisions you are referring to.  Explain how you evaluated these
release provisions and how full and unconditional guarantee meets the definition under
Rule 3-10(h) of Regulation S -X in light of  the customary release provisions disclosed.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and  all applicable Exchange Act rules require .  Since the compa ny 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.

 In responding to our comments, please provide  a written statement from the co mpany
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.

Mr. Sang Park
MagnaChip Semiconductor Corporation
September 2 8, 2012
Page 3

 You may contact Gary Newberry at (202) 551 -3761  or me at (202)  551-3643 if you have
questions regarding comments on the financial statements and related matters.  In this regard, do
not hesitate to contact Martin James, Senior Assistant Chief Accountant at (202) 551 -3671.

        Sincerely,

        /s/ Kevin L. Vaughn

        Kevin L. Vaughn
        Accounting Branch Chief