[ORRICK, HERRINGTON & SUTCLIFFE 43RD FLOOR, GLOUCESTER TOWER THE LANDMARK 15 QUEENS ROAD CENTRAL HONG KONG tel 852-2218-9100 fax 852-2218-9200 WWW.ORRICK.COM November 12 , 2010 VIA EDGAR AND HAND DELIVERY Division of Corporate Finance 100 F Street, N.E. Mail Stop Number 3030 Attn: Russell Mancuso, Branch Chief, Legal Gabriel Eckstein Daniel Morris, Special Counsel Martin James Kevin Vaughn, Branch Chief,]
[ORRICK, HERRINGTON & SUTCLIFFE 43RD FLOOR, GLOUCESTER TOWER TEL 852-2218-9100 WWW.ORRICK.COM CERTAIN PORTIONS OF THIS LETTER AS FILED VIA EDGAR HAVE BEEN OMITTED AND FILED SEPARATELY WITH THE COMMISSION. CONFIDENTIAL TREATMENT HAS BEEN REQUESTED WITH RESPECT TO THE OMITTED PORTIONS. OMITTED INFORMATION HAS BEEN REPLACED IN THIS LETTER AS FILED VIA EDGAR WITH A PLACEHOLDER IDENTIFIED BY THE MARK [***].]
[ORRICK, HERRINGTON & SUTCLIFFE 43RD FLOOR, GLOUCESTER TOWER THE LANDMARK 15 QUEENS ROAD CENTRAL HONG KONG tel 852-2218-9100 fax 852-2218-9200 WWW.ORRICK.COM October 26, 2010 VIA EDGAR AND HAND DELIVERY Division of Corporate Finance 100 F Street, N.E. Mail Stop Number 3030 Attn: Russel l Mancuso, Branch Chief, Legal Gabriel Eckstein]
[ORRICK, HERRINGTON & SUTCLIFFE 43RD FLOOR, GLOUCESTER TOWER THE LANDMARK 15 QUEENS ROAD CENTRAL HONG KONG tel 852-2218-9100 fax 852-2218-9200 WWW.ORRICK.COM October 26, 2010 VIA EDGAR AND HAND DELIVERY Division of Corporate Finance 100 F Street, N.E. Mail Stop Number 3030 Attn: Russel l Mancuso, Branch Chief, Legal Gabriel Eckstein]
[AMENDMENT NO. 4 FORM S-1 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 SEMILEDS CORPORATION Delaware 3674 20-2735523 3F, No.11 Ke Jung Rd., Chu-Nan Site, National Corporate Research Ltd. COPIES TO: Mark J. Lee Jeffrey D. Saper ORRICK, HERRINGTON & SUTCLIFFE LLP WILSON SONSINI GOODRICH & ROSATI Approximate date of commencement of proposed sale to the public: o o o] [SEMILEDS CORPORATION INDEMNIFICATION AGREEMENT Agreement Company Indemnitee This Indemnification Agreement (this RECITALS The Company and Indemnitee recognize the increasing difficulty in obtaining liability insurance for directors, officers and key employees, the significant increases in the cost of such insurance and the general reductions in the coverage of such insurance. The Company and Indemnitee further recognize the substantial increase in] [COLLABORATION AND DISTRIBUTION AGREEMENT Agreement Effective Date Intematix SemiLEDs This Collaboration and Distribution Agreement (the BACKGROUND A.SemiLEDs is in the business of LED, general illumination, and related lighting products. B.Intematix is in the business of phosphor products and phosphor related LED, signage, display and lighting products. C.SemiLEDs and Intematix desire (1) to cooperate in the development of optimized phosphors,] [Consent of Independent Registered Public Accounting Firm The Board of Directors and Stockholders We consent to the use of our report, dated October 26, 2010, included herein and to the reference to our firm under the heading Experts in the prospectus. (signed) KPMG LLP Boise, Idaho EX-23.1 4 a2200521zex-23_1.htm EX-23.1]
[AMENDMENT NO. 4 FORM S-1 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 SEMILEDS CORPORATION Delaware 3674 20-2735523 3F, No.11 Ke Jung Rd., Chu-Nan Site, National Corporate Research Ltd. COPIES TO: Mark J. Lee Jeffrey D. Saper ORRICK, HERRINGTON & SUTCLIFFE LLP WILSON SONSINI GOODRICH & ROSATI Approximate date of commencement of proposed sale to the public: o o o] [SEMILEDS CORPORATION INDEMNIFICATION AGREEMENT Agreement Company Indemnitee This Indemnification Agreement (this RECITALS The Company and Indemnitee recognize the increasing difficulty in obtaining liability insurance for directors, officers and key employees, the significant increases in the cost of such insurance and the general reductions in the coverage of such insurance. The Company and Indemnitee further recognize the substantial increase in] [COLLABORATION AND DISTRIBUTION AGREEMENT Agreement Effective Date Intematix SemiLEDs This Collaboration and Distribution Agreement (the BACKGROUND A.SemiLEDs is in the business of LED, general illumination, and related lighting products. B.Intematix is in the business of phosphor products and phosphor related LED, signage, display and lighting products. C.SemiLEDs and Intematix desire (1) to cooperate in the development of optimized phosphors,] [Consent of Independent Registered Public Accounting Firm The Board of Directors and Stockholders We consent to the use of our report, dated October 26, 2010, included herein and to the reference to our firm under the heading Experts in the prospectus. (signed) KPMG LLP Boise, Idaho EX-23.1 4 a2200521zex-23_1.htm EX-23.1]
