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United States securities and exchange commission logo
May 1, 2023
Silvia Su
Vice President, Finance and Accounting Management Center
CHIPMOS TECHNOLOGIES INC
No.1, R&D Road 1, Hsinchu Science Park
Hsinchu 300-092, Taiwan, Republic of China
Re: CHIPMOS
TECHNOLOGIES INC
Form 20-F for the
Year Ended December 31, 2022
Filed April 13,
2023
File No. 001-37928
Dear Silvia Su:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 20-F for the Year Ended December 31, 2022
Risks Factors
Risks Relating to Economic Conditions and the Financial Markets, page 3
1. We note your risk
factor indicating that global inflation and financial market disruptions
could materially and
adversely affect your business and results of operations. In future
filings, please expand
your disclosure to discuss if recent inflationary pressures have
materially impacted the
company s operations, clarify the resulting impact on the
company, and identify
actions planned or taken, if any, to mitigate inflationary pressures.
In this regard, please
also identify the types of inflationary pressures you are facing and
how your business has
been affected.
Item 5. Operating and Financial Review and Prospects
Results of Operations, page 48
2. Please revise to
provide a more comprehensive and quantified discussion and analysis of
Silvia Su
CHIPMOS TECHNOLOGIES INC
May 1, 2023
Page 2
the factors that impacted your results between comparative periods.
For example, you
disclose that revenue decreased 14% in 2022 principally due to
decreased customer
demand without discussing any underlying drivers for the significant
decrease in customer
demand. In future filings, please revise your discussion to include an
analysis of the
known material trends, events, demands, commitments and uncertainties,
and quantify and
discuss the underlying drivers or metrics to illustrate the change in
demand (e.g., volume,
product mix, utilization rates and average selling price).
Liquidity and Capital Resources, page 50
3. Your discussion of cash flows from operating activities should be a
comparative analysis
of material changes in this amount between periods. In your analysis,
please include a
discussion of the underlying reasons for material changes in working
capital items that
affect operating cash flows. For example, describe how changes in
accounts and notes
receivable and inventories contributed to the changes in cash flows
from operating
activities. Refer to Section IV.B.1 of SEC Release No. 33-8350.
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.
You may contact SiSi Cheng at 202-551-5004 or Ernest Greene at
202-551-3733 with
any questions.
FirstName LastNameSilvia Su Sincerely,
Comapany NameCHIPMOS TECHNOLOGIES INC
Division of
Corporation Finance
May 1, 2023 Page 2 Office of
Manufacturing
FirstName LastName