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May 21, 2020
Zeynep Hakimoglu
President and Chief Executive Officer
ClearOne, Inc.
5225 Wiley Post Way, Suite 500
Salt Lake City, UT 84116
Re:ClearOne, Inc.
Registration Statement on Form S-3
Filed May 7, 2020
File No.333-238085
Dear Ms. Hakimoglu:
            We have limited our review of your registration statement to those issues that we have
addressed in our comment.  In our comment we may ask you to provide us information so that
we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe that our comment applies to your facts and
circumstances or do not believe that an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to the comment, we may have additional comments.
Registration Statement on Form S-3 filed May 7, 2020
General
1.We note that your forum selection provision identifies the Court of Chancery of the State
of Delaware as the exclusive forum for certain litigation, including any “derivative
action.”  Please disclose whether this provision applies to actions arising under the
Securities Act or Exchange Act.  In that regard, we note that Section 27 of the Exchange
Act creates exclusive federal jurisdiction over all suits brought to enforce any duty or
liability created by the Exchange Act or the rules and regulations thereunder, and Section
22 of the Securities Act creates concurrent jurisdiction for federal and state courts over all
suits brought to enforce any duty or liability created by the Securities Act or the rules and
regulations thereunder.  If the provision applies to Securities Act claims, please revise
your prospectus to state that there is uncertainty as to whether a court would enforce such

 FirstName LastNameZeynep Hakimoglu
 Comapany NameClearOne, Inc.
 May 21, 2020 Page 2
 FirstName LastName
Zeynep Hakimoglu
ClearOne, Inc.
May 21, 2020
Page 2
provision and that investors cannot waive compliance with the federal securities laws and
the rules and regulations thereunder.  Please include appropriate risk factor disclosure
related to your exclusive forum provision.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment before the requested effective date of the registration
statement.
            Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 or Asia Timmons-
Pierce, Special Counsel, at (202) 551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing