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 13, 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:

Request to Withdraw Acceleration Request of MagnaChip Semiconductor S.A. (the “Company”), MagnaChip Semiconductor Finance Company (the “Co-Issuer”, and together with the Company, the “Issuers”) and the Guarantors ( as defined below)

Registration Statement on Form S-1 (File No. 333-168790)

Ladies and Gentlemen:

Each of the Issuers and each of the guarantors listed on the Table of Additional Registrants in the above-referenced Registration Statement (the “Guarantors”) hereby withdraws its prior request dated as of October 12, 2010 to accelerate the effective date of the above-referenced Registration Statement. Thank you for the Staff’s cooperation in connection with this matter.

[Remainder of Page Intentionally Left Blank]

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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				Name:		Margaret Sakai
		Director				Title:		Chief Financial Officer
MAGNACHIP SEMICONDUCTOR LLC						MAGNACHIP SEMICONDUCTOR SA HOLDINGS LLC
By:		/s/ Margaret Sakai				By:		/s/ Margaret Sakai
Name:		Margaret Sakai				Name:		Margaret Sakai
Title:		Chief Financial Officer				Title:		Chief Financial Officer
MAGNACHIP SEMICONDUCTOR B.V.						MAGNACHIP SEMICONDUCTOR, INC. (USA)
By:		/s/ John McFarland				By:		/s/ Margaret Sakai
Name:		John McFarland				Name:		Margaret Sakai
Title:		Authorized Representative				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				Name:		Margaret Sakai
Title:		Company Secretary				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				Name:		Margaret Sakai
Title:		Director				Title:		Director
MAGNACHIP SEMICONDUCTOR HOLDING COMPANY LIMITED
By:		/s/ Margaret Sakai
Name:		Margaret Sakai
Title:		Chief Financial Officer

Signature Page to S-1 Request to Withdraw Acceleration Request Letter

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cc:	Micheal Reagan

Stuart Ogg