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United States securities and exchange commission logo
December 19, 2023
Natasha Fernandes
Chief Financial Officer
IMAX CORP
902 Broadway, Floor 20
New York, NY 10010
Re: IMAX CORP
Form 10-K for
Fiscal Year Ended December 31, 2022
Form 10-Q for
Fiscal Quarter Ended September 30, 2023
File No. 001-35066
Dear Natasha Fernandes:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-Q for the Period Ended September 30, 2023
Note 13. Segment Reporting, page 37
1. Prior to the first
quarter of 2023, you determined you had seven reportable segments. You
revised your internal
segment reporting and have now determined you only have two
reportable segments.
Please help us better understand how you determined you have two
reportable segments
pursuant to the guidance of ASC 280. Please specifically address the
following:
Tell us how you
identified your operating segments based on the criteria provided in
ASC 280-10-50-1
through 50-9 and provide us with a list of these operating
segments;
Help us better
understand how you determined your CODM;
Tell us each of the
individuals that report to the CODM and identify and describe the
role of each
segment manager;
Tell us how often
the CODM meets with his/her direct reports, the financial
information the
CODM reviews to prepare for those meetings, the financial
Natasha Fernandes
IMAX CORP
December 19, 2023
Page 2
information discussed in those meetings, and who else attends
those meetings;
Describe the information regularly provided to both the CODM
and the Board of
Directors, and how frequently it is prepared;
Explain how budgets are prepared, who approves the budget at
each step of the
process, the level of detail discussed at each step, and the
level at which the CODM
makes changes to the budget;
Describe the basis for determining the compensation for each of
the individuals that
report to the CODM; and
To the extent you aggregated operating segments to determine
your reportable
segments, please specifically provide us with a summary of the
aggregation analysis
you performed pursuant to ASC 280-10-50-11 in determining it was
appropriate to
aggregate.
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.
Please contact Nudrat Salik at 202-551-3692 or Terence O'Brien at
202-551-3355 with
any questions.
Sincerely,
FirstName LastNameNatasha Fernandes
Division of
Corporation Finance
Comapany NameIMAX CORP
Office of
Industrial Applications and
December 19, 2023 Page 2 Services
FirstName LastName