July 10, 2019

Patrick McClymont
Chief Financial Officer
IMAX Corporation
2525 Speakman Drive
Mississauga, Ontario
Canada L5K 1B1

       Re: IMAX Corporation
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 26, 2019
           Form 10-Q for the Quarterly Period Ended March 31, 2019
           Filed April 26, 2019
           File No. 001-35066

Dear Mr. McClymont:

       We have reviewed your filing and have the following comment. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-Q for the Quarterly Period Ended March 31, 2019

Condensed Consolidated Statements of Operations, page 6

1.    We note that your statement of operations includes two captions for
income from
      operations, the second of which is labeled as income from operations
before income
      taxes. Please tell us how this presentation is consistent with the
guidance in Rule 5-03 of
      Regulation S-X. Specifically address why you label an amount that
includes interest
      income, interest expense and nonservice retirement expense as income from
operations
      although, for example, Rules 5-03 (b)7 - 9 of Regulation S-X include
interest income and
      expense as non-operating items. Further, tell why you present the change
in fair value of
      financial instruments below the second caption and whether the amount is
presented net of
      applicable taxes.
 Patrick McClymont
IMAX Corporation
July 10, 2019
Page 2

        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 Kristin Lochhead, Staff Accountant, at (202) 551-3664 or
Gary Todd,
Senior Accountant, at (202) 551-3605 with any questions.



FirstName LastNamePatrick McClymont                       Sincerely,
Comapany NameIMAX Corporation
                                                          Division of
Corporation Finance
July 10, 2019 Page 2                                      Office of Electronics
and Machinery
FirstName LastName