corresp
 

(IMAX LOGO)
     
Ms. Angela Crane
  November 26, 2007
Branch Chief
   
Division of Corporation Finance
   
Securities and Exchange Commission
   
Washington, D.C. 20549
   
USA
   
     
Re:
  IMAX Corporation (the “Company”)
 
  Response to SEC Comment Letter dated August 17, 2007
 
  File No. 000-24216
Dear Ms. Crane:
We would like to again express our appreciation for the time and consideration provided by the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Staff”) concerning the matters presented in the Company’s letter dated September 26, 2007 and the revised Exhibit 1 presented to the Staff on October 24, 2007.
During our discussions on November 2, 2007, the Staff noted certain areas presented in Exhibit 1 where it would require clarification or additional information from the Company in order to further its review. As a result, the Company has provided the following further revised Exhibit 1 (clean and blacklined to show changes) to its October 24, 2007 response. The revised Exhibit 1, which is attached, documents such information and should replace Exhibit 1 of the October 24, 2007 submission.
     
 
  IMAX CORPORATION
 
  2525 Speakman Drive
 
  Mississauga, Ontario
 
  Canada L5K 1B1
 
  t 905.403.6500 f 905.403.6450
 
  www.imax.com

 


 

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Should you require clarification or have any further questions, please contact me at (212) 821-0166. The Company stands ready to assist the Staff in any way possible in connection with the matters addressed in this letter.
Thank you,
         
     
/s/ Joseph Sparacio      
Joseph Sparacio     
Chief Financial Officer     
 
     
cc:
  Kevin Kuhar, Staff Accountant, Division of Corporation Finance, Securities and Exchange Commission
 
  Jodie Hancock, Senior Accountant, Corporate Finance Branch, Ontario Securities Commission
 
  PricewaterhouseCoopers LLP
 
  Robert Lister, IMAX Corporation
 
  Members of Audit Committee, IMAX Corporation

2


 

Exhibit 1
Pages A-1 to A-10
[Omitted pursuant to a request for confidential treatment and submitted separately with the Commisssion]

A-1