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                             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