SEC Comment Letter for MAGNACHIP SEMICONDUCTOR Corp (MX) (CIK 0001325702) (MX) — Aug 2, 2017
MAGNACHIP SEMICONDUCTOR Corp (MX) (CIK 0001325702)
Date: Aug. 2, 2017 · CIK: 0001325702 · Accession: 0000000000-17-027160
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34791
Letter
Mail Stop 3030 August 2, 201 7 Via E -mail Jonathan W. Kim Chief Financial 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 the Fiscal Year Ended December 31, 2016 Filed February 2 1, 2017 File No. 001-34791
Dear Mr. Kim:
We have reviewed your filing an d have the following comment . In our comment s, we may ask you to provide us with in formation so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to yo ur facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2016
Consolidated Financial Statements
Note 4. Inventory, page 96
1. We note that you establish a reserve for inventory and present a roll -forward in the second table on page 96. Please address the following: Tell us what the reduction of $297 thousand presented as a ‘change in reserve’ in Fiscal 2 015 represents. Tell us whether the ‘change in reserve’ caption is a net amount for each period presented in the table and if so, provide us with the gross amount of impairment charges recorded pursuant to ASC 330 -10-35-2 and the gross amounts of any recoveries or other items that reduced the caption amount for each period.
Jonathan W. Kim MagnaChip Semiconductor Corporation August 2, 2017 Page 2
Explain to us how your accounting for impaired inventory complies with ASC 330 - 10-35-14 and SAB Topic 5.BB.
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.
You may contact Tara Harkins at (202) 551 -3639 or me at (202) 551 -3671 with any questions.
Sincerely,
/s/ Martin James
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Mail Stop 3030
August 2, 201 7
Via E -mail
Jonathan W. Kim
Chief Financial 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 the Fiscal Year Ended December 31, 2016
Filed February 2 1, 2017
File No. 001-34791
Dear Mr. Kim:
We have reviewed your filing an d have the following comment . In our comment s, we
may ask you to provide us with in formation so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comment applies to yo ur facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2016
Consolidated Financial Statements
Note 4. Inventory, page 96
1. We note that you establish a reserve for inventory and present a roll -forward in the
second table on page 96. Please address the following:
Tell us what the reduction of $297 thousand presented as a ‘change in reserve’ in
Fiscal 2 015 represents.
Tell us whether the ‘change in reserve’ caption is a net amount for each period
presented in the table and if so, provide us with the gross amount of impairment
charges recorded pursuant to ASC 330 -10-35-2 and the gross amounts of any
recoveries or other items that reduced the caption amount for each period.
Jonathan W. Kim
MagnaChip Semiconductor Corporation
August 2, 2017
Page 2
Explain to us how your accounting for impaired inventory complies with ASC 330 -
10-35-14 and SAB Topic 5.BB.
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.
You may contact Tara Harkins at (202) 551 -3639 or me at (202) 551 -3671 with any
questions.
Sincerely,
/s/ Martin James
Martin James
Senior Assistant Chief Accountant
Office of Electronics and Machinery