SecProbe.io

October 25, 2011
 Via Facsimile

Ms. Luz Berg Chief Operating Officer and Corporate Secretary
Iveda Solutions, Inc. 1201 South Alma School Road, Suite 8500 Mesa, AZ  85210
RE: Iveda Solutions, Inc.
Item 4.01 Form 8-K Filed October 21, 2011 File No. 0-53285

Dear Ms. Berg:
 We have reviewed your filing and have the following comments.  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 letter within fi ve business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            1. Please amend your Form 8-K to specifically state whether the former accountant resigned,
declined to stand for re-election or was dismi ssed, and the specific date, as required by Item
304(a)(1)(i) of Regulation S-K.
 2. Item 304(a)(1)(ii) of Regulation S-K requires a statement whether the accountant's reports on
the financial statements for either of the pa st two years contained an adverse opinion or a
disclaimer of opinion or was qualified or m odified as to uncertainty, audit scope or
accounting principles; and a de scription of the nature of  each such adverse opinion,
disclaimer of opinion, modificat ion or qualification.  This w ould include disclosure of
uncertainty regarding the ability to continue as a going concern in the accountant’s reports.  It
appears that the reports included in your  December 31, 2010 and 2009 Forms 10-K contained
disclosure of uncertainty regarding the ability  to continue as a goi ng concern.  As such,
please revise your disclosure accord ingly in an amended Form 8-K.

Ms. Luz Berg Iveda Solutions, Inc. October 25, 2011 Page 2

 3. To the extent that you make changes to the Fo rm 8-K to comply with our comments, please
obtain and file an updated Exhibit 16 letter fr om the former accountants stating whether the
accountant agrees with the statements  made in your amended Form 8-K.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.
You may contact me at (202)  551-3866 with any questions.

 Sincerely,
        /s/ Jeffrey Gordon
      Jeffrey Gordon  Staff Accountant