SEC Comment Letter for MAGNACHIP SEMICONDUCTOR Corp (MX) (CIK 0001325702) (MX) — Aug 30, 2017
MAGNACHIP SEMICONDUCTOR Corp (MX) (CIK 0001325702)
Date: Aug. 30, 2017 · CIK: 0001325702 · Accession: 0000000000-17-030731
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File numbers found in text: 001-34791
Letter
Mail Stop 3030 August 30, 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 August 16, 2017 response to our comment letter and have the following comment. In our comme nts, we may ask you to provide us with information 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 d o not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to co mments in our August 2, 2017 letter .
Form 10 -K for the year ended December 31, 2017
Consolidated Financial Statements
Note 4. Inventory, page 96
1. We note your response to comment 1. In future periods in which you present the roll - forward, revise the table to separately show the gross amounts of inventory impairment charges recorded pursuant to ASC 330 -10-35-2 in each period. Further, revise the inventory discussion in the Critical Accounting Policies and Estimates section of Management’s Discussion and Analysis to quantify the impairment charges recorded in each period. When material in future periods, revise your Gross Profit discussions on pages 61 and 66 to disclose
Jonathan W. Kim MagnaChip Semiconductor Corporation August 30, 2017 Page 2
the impact of the sale of previously impaired inventory on gross margin s. Refer to Item 303(a)(3) of Regulation S -K and Section V of SEC Release 33 -3850.
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 absen ce 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 30, 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 August 16, 2017 response to our comment letter and have the
following comment. In our comme nts, we may ask you to provide us with information 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 d o not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Unless we note otherwise, our references to prior comments are to co mments in our August 2,
2017 letter .
Form 10 -K for the year ended December 31, 2017
Consolidated Financial Statements
Note 4. Inventory, page 96
1. We note your response to comment 1. In future periods in which you present the roll -
forward, revise the table to separately show the gross amounts of inventory impairment
charges recorded pursuant to ASC 330 -10-35-2 in each period. Further, revise the inventory
discussion in the Critical Accounting Policies and Estimates section of Management’s
Discussion and Analysis to quantify the impairment charges recorded in each period. When
material in future periods, revise your Gross Profit discussions on pages 61 and 66 to disclose
Jonathan W. Kim
MagnaChip Semiconductor Corporation
August 30, 2017
Page 2
the impact of the sale of previously impaired inventory on gross margin s. Refer to Item
303(a)(3) of Regulation S -K and Section V of SEC Release 33 -3850.
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 absen ce 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