corresp
August 30, 2006
VIA EDGAR AND OVERNIGHT DELIVERY
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
Mail Stop 6010
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Attention:
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Ms. Jeanne Bennett |
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Re:
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Amkor Technology, Inc. |
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Form 8-K for Item 4.02(a) |
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Filed on August 16, 2006 |
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File No. 000-29472 |
Ladies and Gentlemen:
On behalf of Amkor Technology, Inc. (Amkor or the Company), we submit this letter in
response to the comments of the Staff of the Division of Corporation Finance (the Staff) of the
Securities and Exchange Commission (the Commission) to the document referenced above, as set
forth in your letter dated August 22, 2006 to the Company. For ease of reference, the text of the
Staffs numbered comment has been provided herein in italics. The Companys response follows the
numbered comment.
Form 8-K Filed August 16, 2006
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We note that you intend to file restated financial statements. However, you
have not indicated when you intend to do so. Please tell us how and when you intend to
file restated financial statements. We may have further comment after you file the
restated financial statements. |
Companys Response:
As stated in the Item 4.02 Form 8-K filed by the Company on August 16, 2006, the
board of directors of Amkor has established a special committee (the Special
Committee) to conduct a review of the Companys historical stock option
Securities and Exchange Commission
August 30, 2006
Page 2
grant
practices. In response to the Staffs inquiry, the Company asked counsel to the Special Committee for an
estimate of when the Special Committees review would be completed. The Company was informed that,
pending completion of certain data mining activities, the Special Committee could not give an
effective estimate for completion. The Company believes that it will not be in a position to file restated financial
statements until the Special Committees review is substantially complete. For these reasons, the Company is not in a position to estimate when it will be able to effect the
required restatements and file amended reports with the Commission.
To date, the Company has not concluded as to the form of
any required restatement. However, among other potential filings, the Company currently
anticipates that it will file an amendment to its Form 10-K for the fiscal year ended
December 31, 2005.
In addition to our response to the Staffs comment noted above, the Company acknowledges that:
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the Company is responsible for the adequacy and accuracy of the disclosure in
its filing with the Commission; |
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the Staffs comments or changes to disclosure in response to the Staffs
comments do not foreclose the Commission from taking any action with respect to the
Companys filing; and |
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the Company may not assert the Staffs comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the
United States. |
Securities and Exchange Commission
August 30, 2006
Page 3
Please direct your questions or comments to the undersigned at (202) 772-1827. Thank you for
your assistance.
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Very truly yours,
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
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/s/ Robert Sanchez
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Robert Sanchez |
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cc:
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Kenneth T. Joyce, Executive Vice President and Chief Financial Officer |
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Jerry Allison, Esq., Vice President and Assistant General Counsel |
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Amkor Technology, Inc. |