Correspondence 0001171843-23-004776 from Himax Technologies, Inc. (HIMX) (CIK 0001342338) (HIMX)
Himax Technologies, Inc. (HIMX) (CIK 0001342338)
Date: July 28, 2023 · CIK: 0001342338 · Accession: 0001171843-23-004776
AI Filing Summary & Sentiment
File numbers found in text: 000-51847
Referenced dates: July 24, 2023
Letter
Office of Manufacturing Division of Corporation Finance Attention: Andri Carpenter, Anne McConnell Himax Technologies, Inc. Form 20-F for the Fiscal Year Ended December 31, 2022 Form 6-K filed on February 9, 2023 File No. 000-51847
Re:
Dear Andri Carpenter, Anne McConnell:
This letter sets forth the response of Himax Technologies, Inc. (“Himax” or the “Company”) to the comments (the “Comments”) the Company received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in a letter dated July 24, 2023.
For your convenience, we have included herein the Comments in bold, and the Company’s responses are set forth immediately below the Comments.
* * * *
Form 6-K filed on February 9, 2023
Exhibit 99.1, page 1
We have considered your response to prior comment 1; however, we continue to believe cash compensation paid to employees is a normal operating expense necessary to operate your business and excluding such costs from your non-IFRS financial measures is inconsistent with Question 100.01 of the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Regulation G. Please revise your non-IFRS measures in future filings to remove this adjustment.
The Company respectfully submits that it will follow the Commission’s suggestion and revise its non-IFRS measures in future filings to remove the cash compensation adjustment.
***
If you have further questions or comments regarding, or require further information or clarification of, the response provided in this letter or if the Commission has any other questions with respect to Himax’s Form 6-K filed on February 9, 2023, please contact James C. Lin at +852 2533-3368 (james.lin@davispolk.com) of Davis Polk & Wardwell LLP.
Thank you for your time and attention.
Yours sincerely,
/s/ Jessica Pan
Name: Jessica Pan
Title: Chief Financial Officer
cc: Mr. James C. Lin, Partner
Davis Polk & Wardwell LLP
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CORRESP
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filename1.htm
July 28, 2023
Office of Manufacturing
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Andri Carpenter, Anne McConnell
Re:
Himax Technologies, Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Form 6-K filed on February 9, 2023
File No. 000-51847
Dear Andri Carpenter, Anne McConnell:
This letter sets forth the response of Himax Technologies, Inc. (“Himax”
or the “Company”) to the comments (the “Comments”) the Company received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) in a letter dated July 24, 2023.
For your convenience, we have included herein the Comments in bold, and the Company’s
responses are set forth immediately below the Comments.
* * * *
Form 6-K filed on February 9, 2023
Exhibit 99.1, page 1
We have considered your response to prior comment 1; however, we continue to believe cash compensation
paid to employees is a normal operating expense necessary to operate your business and excluding such costs from your non-IFRS financial
measures is inconsistent with Question 100.01 of the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Regulation
G. Please revise your non-IFRS measures in future filings to remove this adjustment.
The Company respectfully submits that it will follow the Commission’s suggestion and revise
its non-IFRS measures in future filings to remove the cash compensation adjustment.
***
If you have further questions or comments regarding, or require further information or clarification
of, the response provided in this letter or if the Commission has any other questions with respect to Himax’s Form 6-K filed on
February 9, 2023, please contact James C. Lin at +852 2533-3368 (james.lin@davispolk.com) of Davis Polk & Wardwell LLP.
Thank you for your time and attention.
Yours sincerely,
/s/ Jessica Pan
Name: Jessica Pan
Title: Chief Financial Officer
cc:
Mr. James C. Lin, Partner
Davis Polk & Wardwell LLP