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United States securities and exchange commission logo
February 13, 2024
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 reviewed your January 29, 2024 response to our comment
letter and have the
following comments.
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. Unless
we note otherwise, any references to prior comments are to comments in
our December 19,
2023 letter.
Form 10-Q for the Period Ended September 30, 2023
Note 13. Segment Reporting, page 37
1. We note your response
to comment 1. We note that the senior management team
including the CODM and
his direct reports meet regularly throughout the year to review
the company's
performance and corporate strategies. Please tell us more about the
financial information
provided and discussed at these meetings, including what type of
financial information
is provided at the operating segment level and any levels below the
operating segment
level.
2. We note that there is a
Chief Executive Officer of IMAX China. Please help us
understand what his
role is. Please help us understand whether there is discrete financial
information available
for IMAX China and who reviews this financial information.
3. We note on your website
you also indicate that management includes Craig Dehmel who
Natasha Fernandes
IMAX CORP
February 13, 2024
Page 2
is the EVP, Head of Global Distribution, IMAX Entertainment and SVP,
IMAX
Corporation as well as Bruce Markoe who is the Senior Vice President
of Post
Production/Operations and DMR. Please tell us the role of these
positions.
4. The titles of your management team refer to different entities,
including IMAX
Entertainment, IMAX Corporation, IMAX Global Theaters, and IMAX China.
Please help
us understand what each of these entities represent, including the
operations associated
with each entity, and how they correlate to your operating segments.
5. The Content Solutions segment was managed by your CODM, Richard
Gelfond, as of
September 30, 2023 and December 31, 2023 as the Chief Content Officer
position was
vacant. Please tell us the current status of the Chief Content Officer
position.
6. We note that annual budgets are built up from the component unit
level, which is below
the operating segment level. Please provide us with the following
additional details
regarding your component units:
Please tell us what your components consisted of as of September
30, 2023 and
December 31, 2023 under each operating segment;
Please tell us what discrete financial information is available at
the component level
as well as who it is provided to and how frequently; and
Please tell us whether there are component level managers. If so,
please share who
they report to and their roles.
Please contact Nudrat Salik at 202-551-3692 or Terence O'Brien at
202-551-3355 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
FirstName LastNameNatasha Fernandes
Division of
Corporation Finance
Comapany NameIMAX CORP
Office of
Industrial Applications and
February 13, 2024 Page 2 Services
FirstName LastName