Siliconware Precision Industries (SPILA) Inactive
Filed: 24 Feb 16, 12:00am
February 24, 2016
VIA EDGAR
Office of Mergers and Acquisitions
United States Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Mr. David L. Orlic, Special Counsel
| Re: | Siliconware Precision Industries Co., Ltd. |
Solicitation/Recommendation Statement on Schedule 14D-9
Filed January 7, 2016
File No. 005-79592
Gentlemen:
Siliconware Precision Industries Co., Ltd. (the “Company”, “we” or “our”) enclose herewith for filing via EDGAR with the United States Securities and Exchange Commission (the “Commission”) Amendment No. 2 to the Company’s Solicitation/Recommendation Statement on Schedule 14D-9, initially filed on January 7, 2016 (the “Schedule 14D-9”), as amended by Amendment No. 1 filed on January 26, 2016. The Company’s Schedule 14D-9 has been revised to reflect the Company’s response to the comment letter, dated January 27, 2016 (the “Comment Letter”) received from the staff of the Commission (the “Staff”).
In this letter, we have recited the comment from the Staff in italicized, bold type and have followed the comment with the Company’s response.
Recommendation
| 1. | We note the response to prior comment 1. Under Rule 14e-2(a), the company’s statement of position must take one of three forms, namely, that the company: recommends acceptance or rejection of the offer; express no opinion and remains neutral toward the offer; or is unable to take a position with respect to the offer. In this case, having stated that the offer is unfair and significantly risky, and that the offer price is unreasonable, the company is not remaining neutral towards the offer and has taken a position with respect thereto. Please therefore make the statement required by Rule 14e-2(a)(1) or provide a legal analysis supporting the position that the company has complied with the rule, citing all relevant legal authority. Refer to SEC Release No. 34-16384 (November 29, 1979). |
In response to the Staff’s comment, the Company has revised Item 4 of the Schedule 14D-9 to make the statement required by Rule 14e-2(a)(1).
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Please feel free to contact Eva Chen, Chief Financial Officer, at +886(4) 2534-1525 (ext. 1528) if you would like further clarification or additional information.
| Sincerely, | ||
| Siliconware Precision Industries Co., Ltd. | ||
| By: | /s/ Eva Chen | |
| Eva Chen | ||
| Chief Financial Officer | ||