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SEC Comment Letter for MAGNACHIP SEMICONDUCTOR Corp (MX) (CIK 0001325702) (MX) — Sep 3, 2015

MAGNACHIP SEMICONDUCTOR Corp (MX) (CIK 0001325702)
Date: Sept. 3, 2015 · CIK: 0001325702 · Accession: 0000000000-15-044353

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: August 7, 2015

Date
September 3, 2015
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
MAGNACHIP SEMICONDUCTOR Corp (MX) (CIK 0001325702)

Letter

Mail Stop 4628 September 3, 2015 Via E -mail Young -Joon Kim Chief Executive Officer MagnaChip Semiconductor Corporation c/o MagnaChip Semiconductor S.A. 1, Allée Scheffer , L-2520 Luxembourg, Grand Duchy of Luxembourg

Re: MagnaChip Semiconductor Corporation Form 10-K for Fiscal Year Ended December 31, 2014 Filed May 28, 2015 File No. 1 -34791

Dear Mr.Kim:

We refer you to our comment letter dated August 7, 2015 , regarding business contacts with Sudan and Syria. We have completed our review of this subject matter. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the c ompany or 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. We urge all persons who are responsible for the accuracy an d 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 rules require.

Sincerely,
/s/ Cecilia Blye

Show Raw Text
Mail Stop 4628

September 3,  2015

Via E -mail
Young -Joon Kim
Chief Executive Officer
MagnaChip Semiconductor Corporation
c/o MagnaChip Semiconductor S.A.
1, Allée Scheffer , L-2520
Luxembourg, Grand Duchy of Luxembourg

Re: MagnaChip Semiconductor Corporation
 Form 10-K for Fiscal Year Ended December 31, 2014
 Filed May 28, 2015
 File No. 1 -34791

Dear Mr.Kim:

We refer you to our comment letter dated August 7, 2015 , regarding business contacts
with Sudan and Syria.  We have completed our review of this subject matter.  We remind you
that our comments or changes to disclosure in response to our comments do not foreclose the
Commission from taking any action with respect to the c ompany or 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.  We urge all persons who are
responsible for the accuracy an d 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 rules
require.

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  Amanda Ravitz
  Assistant Director
 Division of Corporation Finance

Young -Soon Kim
MagnaChip Semiconductor Corporation
September 3 , 2015
Page 2

   Theodore S. Kim
  Chief Compliance Officer ,
  Executive Vice President,
  General Counsel and Secretary
 MagnaChip Semiconductor Corporation

  W. Stuart Ogg
  Partner
  Jones Day