SEC Company Response from MAGNACHIP SEMICONDUCTOR Corp (MX) (CIK 0001325702) (MX) — Oct 12, 2010
MAGNACHIP SEMICONDUCTOR Corp (MX) (CIK 0001325702)
Date: Oct. 12, 2010 · CIK: 0001325702 · Accession: 0001193125-10-227485
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-168790
Letter
Acceleration Request
MAGNACHIP SEMICONDUCTOR S.A.
MAGNACHIP SEMICONDUCTOR FINANCE COMPANY
c/o MagnaChip Semiconductor S.A.
74, rue de Merl
B.P. 709 L-2146 Luxembourg R.C.S.
Luxembourg, B97483
VIA EDGAR AND FACSIMILE
October 12, 2010
Division of Corporation Finance
Mail Stop 3561
United States Securities and Exchange Commission
100 F Street, N.E.,
Washington, D.C. 20549
Attention: Tim Buchmiller, Senior Attorney
Re: Acceleration Request of MagnaChip Semiconductor S.A. (the “Company”) and
MagnaChip Semiconductor Finance Company (the “Co-Issuer”, and together with
the Company, the “Issuers”) and the Guarantors ( as defined below)
Registration Statement of Form S-1 (File No. 333-168790)
Ladies and Gentlemen:
Pursuant to Rule 461 of the Rules and Regulations of the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended (the “Securities Act”), the undersigned hereby request that the effective date of the above-referenced Registration Statement be accelerated so that the Registration Statement, as then amended, will become effective under the Securities Act by 2:00 p.m. (Eastern Time) on Wednesday, October 13, 2010, or as soon thereafter as practicable.
The disclosure in the Registration Statement is the responsibility of the Issuers and the guarantors, listed on the Table of Additional Registrants in the Registration Statement (the “Guarantors”). Each of the Issuers and the Guarantors acknowledge that staff comments or changes in response to staff comments in the disclosure in the Registration Statement may not be asserted as a defense in any proceeding which may be brought by any person with respect to this matter. Each of the Issuers and the Guarantors also represent to the Commission that should the Commission or the staff acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement and each of the Issuers and the Guarantors represent that they will not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Each of the Issuers and the Guarantors further acknowledge that the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective does not relieve the Issuers and the Guarantors from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement.
Very truly yours,
MAGNACHIP SEMICONDUCTOR S.A.
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CORRESP 1 filename1.htm Acceleration Request MAGNACHIP SEMICONDUCTOR S.A. MAGNACHIP SEMICONDUCTOR FINANCE COMPANY c/o MagnaChip Semiconductor S.A. 74, rue de Merl B.P. 709 L-2146 Luxembourg R.C.S. Luxembourg, B97483 VIA EDGAR AND FACSIMILE October 12, 2010 Division of Corporation Finance Mail Stop 3561 United States Securities and Exchange Commission 100 F Street, N.E., Washington, D.C. 20549 Attention: Tim Buchmiller, Senior Attorney Re: Acceleration Request of MagnaChip Semiconductor S.A. (the “Company”) and MagnaChip Semiconductor Finance Company (the “Co-Issuer”, and together with the Company, the “Issuers”) and the Guarantors ( as defined below) Registration Statement of Form S-1 (File No. 333-168790) Ladies and Gentlemen: Pursuant to Rule 461 of the Rules and Regulations of the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended (the “Securities Act”), the undersigned hereby request that the effective date of the above-referenced Registration Statement be accelerated so that the Registration Statement, as then amended, will become effective under the Securities Act by 2:00 p.m. (Eastern Time) on Wednesday, October 13, 2010, or as soon thereafter as practicable. The disclosure in the Registration Statement is the responsibility of the Issuers and the guarantors, listed on the Table of Additional Registrants in the Registration Statement (the “Guarantors”). Each of the Issuers and the Guarantors acknowledge that staff comments or changes in response to staff comments in the disclosure in the Registration Statement may not be asserted as a defense in any proceeding which may be brought by any person with respect to this matter. Each of the Issuers and the Guarantors also represent to the Commission that should the Commission or the staff acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement and each of the Issuers and the Guarantors represent that they will not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Each of the Issuers and the Guarantors further acknowledge that the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective does not relieve the Issuers and the Guarantors from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement. Very truly yours, MAGNACHIP SEMICONDUCTOR S.A. MAGNACHIP SEMICONDUCTOR FINANCE COMPANY By: /s/ John McFarland By: /s/ Margaret Sakai Name: John McFarland Title: Director Name: Margaret Sakai Title: Chief Financial Officer MAGNACHIP SEMICONDUCTOR LLC MAGNACHIP SEMICONDUCTOR SA HOLDINGS LLC By: /s/ Margaret Sakai By: /s/ Margaret Sakai Name: Margaret Sakai Title: Chief Financial Officer Name: Margaret Sakai Title: Chief Financial Officer MAGNACHIP SEMICONDUCTOR B.V. MAGNACHIP SEMICONDUCTOR, INC. (USA) By: /s/ John McFarland By: /s/ Margaret Sakai Name: John McFarland Title: Authorized Representative Name: Margaret Sakai Title: Chief Financial Officer MAGNACHIP SEMICONDUCTOR LTD (UNITED KINGDOM) MAGNACHIP SEMICONDUCTOR LTD (HONG KONG) By: /s/ John McFarland By: /s/ Margaret Sakai Name: John McFarland Title: Company Secretary Name: Margaret Sakai Title: Director By: /s/ Brent Rowe Name: Brent Rowe Title: Director MAGNACHIP SEMICONDUCTOR LTD (TAIWAN) MAGNACHIP SEMICONDUCTOR INC. (JAPAN) By: /s/ Margaret Sakai By: /s/ Margaret Sakai Name: Margaret Sakai Title: Director Name: Margaret Sakai Title: Director MAGNACHIP SEMICONDUCTOR HOLDING COMPANY LIMITED By: /s/ Margaret Sakai Name: Margaret Sakai Title: Chief Financial Officer Signature Page to S-1 Acceleration Request Letter cc: Micheal Reagan Stuart Ogg