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SEC Comment Letter for SEQUANS COMMUNICATIONS (SQNS) (CIK 0001383395) (SQNS) — Dec 21, 2018

SEQUANS COMMUNICATIONS (SQNS) (CIK 0001383395)
Date: Dec. 21, 2018 · CIK: 0001383395 · Accession: 0000000000-18-039052

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Reasoning

File numbers found in text: 001-35135

Date
December 21, 2018
Author
Deborah Choate
Form
UPLOAD
Company
SEQUANS COMMUNICATIONS (SQNS) (CIK 0001383395)

Letter

December 21, 2018 Deborah Choate Chief Financial Officer Sequans Communications S.A. 15-55 Boulevard Charles de Gaulle 92700 Colombes, France Re:Sequans Communications S.A. Form 20-F for the Fiscal Year Ended December 31, 2017 Filed April 12, 2018 File No. 001-35135 Dear Ms. Choate: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 20-F for the Fiscal Year Ended December 31, 2017 Report of Independent Registered Public Accounting Firm, page F-2 1.We note that your auditor’s opinion refers to International Financial Reporting Standards ("IFRS") as endorsed by the European Union ("EU") while Note 2 to the financial statements state that your financial statements have been prepared in accordance with IFRS as issued by the International Accounting Standards Board ("IASB"). Please amend the filing to include an auditor’s report that opines on your financial statements prepared in accordance with IFRS as issued by the IASB. Please note that your auditor may opine on compliance with both IFRS as issued by the IASB and IFRS as endorsed in the EU, if there is no difference. Refer to Item 17(c) of Form 20-F. In closing, 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.

FirstName LastNameDeborah Choate Comapany NameSequans Communications S.A. December 21, 2018 Page 2 FirstName LastName Deborah Choate Sequans Communications S.A. December 21, 2018 Page 2 You may contact Eric Atallah at (202) 551-3663 or Lynn Dicker, Senior Accountant, at (202) 551-3616 with any questions. Sincerely, Division of Corporation Finance Office of Electronics and Machinery

Show Raw Text
December 21, 2018
Deborah Choate
Chief Financial Officer
Sequans Communications S.A.
15-55 Boulevard Charles de Gaulle
92700 Colombes, France
Re:Sequans Communications S.A.
Form 20-F for the Fiscal Year Ended December 31, 2017
Filed April 12, 2018
File No. 001-35135
Dear Ms. Choate:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2017
Report of Independent Registered Public Accounting Firm, page F-2
1.We note that your auditor’s opinion refers to International Financial Reporting Standards
("IFRS") as endorsed by the European Union ("EU") while Note 2 to the financial
statements state that your financial statements have been prepared in accordance with
IFRS as issued by the International Accounting Standards Board  ("IASB").  Please
amend the filing to include an auditor’s report that opines on your financial statements
prepared in accordance with IFRS as issued by the IASB.  Please note that your
auditor may opine on compliance with both IFRS as issued by the IASB and IFRS
as endorsed in the EU, if there is no difference.  Refer to Item 17(c) of Form 20-F.
            In closing, 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.

 FirstName LastNameDeborah  Choate
 Comapany NameSequans Communications S.A.
 December 21, 2018 Page 2
 FirstName LastName
Deborah  Choate
Sequans Communications S.A.
December 21, 2018
Page 2
            You may contact Eric Atallah at (202) 551-3663 or Lynn Dicker, Senior Accountant, at
(202) 551-3616 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery