Correspondence 0001493152-24-024456 from Clean Energy Technologies, Inc. (CETY) (CIK 0001329606) (CETY)
Clean Energy Technologies, Inc. (CETY) (CIK 0001329606)
Date: June 20, 2024 · CIK: 0001329606 · Accession: 0001493152-24-024456
AI Filing Summary & Sentiment
File numbers found in text: 001-41654, 333-275127
Referenced dates: June 6, 2024
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporate Finance Filed April 17, 2024 Amendment No. 1 to Annual Report on Form 10-K Filed April 19, 2024 File No. 001-41654
Re: Clean Energy Technologies, Inc.
Dear Ms. Liz Packebusch and Ms. Laura Nicholson,
Clean Energy Technologies, Inc. (the “Company”) submits this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated June 6, 2024, relating to the above referenced annual report on Form 10-K for the fiscal year ended December 31, 2023 (the “2023 Annual Report”) and Amendment No. 1 to the 2023 Annual Report. The Company is concurrently filing an Amendment No.2 to the 2023 Annual Report.
The Company also notes the Staff’s verbal comments relating to the annual report on Form 10-K for the fiscal year ended December 31, 2022, filed April 17, 2023 (the “2022 Annual Report”). The Company is concurrently filing an Amendment No.1 to the 2022 Annual Report.
For the Staff’s convenience, the Staff’s comments have been stated below in their entirety, followed by the corresponding responses from the Company.
Annual Report on Form 10-K filed April 17, 2024, as amended on April 19, 2024
General
1. Please revise your filing, as applicable, to provide specific and prominent disclosures about the legal and operational risks associated with China-based companies. For additional guidance, please see the Division of Corporation Finance’s Sample Letter to China-Based Companies issued by the Staff in December 2021 and the Sample Letter to Companies Regarding China-Specific Disclosures issued by the Staff in July 2023. We note your related disclosures in your amended registration statement on Form S-3 (File No. 333-275127).
Response: We note the Staff’s comment and have added the requested disclosures, including a section titled “Disclosures Relating to Our Chinese Operations” before Part I of the Form 10-K/A and a section titled “Risks Related to Doing Business in China” under Item 1A. We have also added similar disclosures in the Amendment No. 1 to the 2022 Annual Report.
We thank the Staff for its review of the foregoing. If you have any questions regarding this matter, please do not hesitate to contact Fang Liu at VCL Law LLP at fliu@vcllegal.com or by telephone at (703) 919-7285.
Very
truly yours,
/s/
Kambiz Mahdi
Show Raw Text
CORRESP
1
filename1.htm
June
20, 2024
VIA
EDGAR
Liz
Packebusch and Laura Nicholson
United
States Securities and Exchange Commission
Division
of Corporate Finance
100
F. Street, N.E.
Washington,
D.C. 20549
Re:
Clean Energy Technologies, Inc.
Annual
Report on Form 10-K
Filed
April 17, 2024
Amendment
No. 1 to Annual Report on Form 10-K
Filed
April 19, 2024
File
No. 001-41654
Dear
Ms. Liz Packebusch and Ms. Laura Nicholson,
Clean
Energy Technologies, Inc. (the “Company”) submits this letter in response to comments from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) contained in its letter dated June 6, 2024, relating
to the above referenced annual report on Form 10-K for the fiscal year ended December 31, 2023 (the “2023 Annual Report”)
and Amendment No. 1 to the 2023 Annual Report. The Company is concurrently filing an Amendment No.2 to the 2023 Annual Report.
The
Company also notes the Staff’s verbal comments relating to the annual report on Form 10-K for the fiscal year ended December 31,
2022, filed April 17, 2023 (the “2022 Annual Report”). The Company is concurrently filing an Amendment No.1 to the
2022 Annual Report.
For
the Staff’s convenience, the Staff’s comments have been stated below in their entirety, followed by the corresponding responses
from the Company.
Annual
Report on Form 10-K filed April 17, 2024, as amended on April 19, 2024
General
1.
Please
revise your filing, as applicable, to provide specific and prominent disclosures about the legal and operational risks associated
with China-based companies. For additional guidance, please see the Division of Corporation Finance’s Sample Letter to China-Based
Companies issued by the Staff in December 2021 and the Sample Letter to Companies Regarding China-Specific Disclosures issued by
the Staff in July 2023. We note your related disclosures in your amended registration statement on Form S-3 (File No. 333-275127).
Response:
We note the Staff’s comment and have added the requested disclosures, including a section titled “Disclosures Relating to
Our Chinese Operations” before Part I of the Form 10-K/A and a section titled “Risks Related to Doing Business in China”
under Item 1A. We have also added similar disclosures in the Amendment No. 1 to the 2022 Annual Report.
We
thank the Staff for its review of the foregoing. If you have any questions regarding this matter, please do not hesitate to contact Fang
Liu at VCL Law LLP at fliu@vcllegal.com or by telephone at (703) 919-7285.
Very
truly yours,
/s/
Kambiz Mahdi
Kambiz
Mahdi
Chief
Executive Officer
cc:
Fang
Liu, Esq.
VCL
Law LLP