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.

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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

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cc:	Micheal Reagan

Stuart Ogg