SEC Comment Letter 0000000000-22-012710 to SolarMax Technology, Inc. (SMXT)
SolarMax Technology, Inc.
Date: Nov. 23, 2022 · CIK: 0001519472 · Accession: 0000000000-22-012710
AI Filing Summary & Sentiment
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File numbers found in text: 333-266206
Letter
United States securities and exchange commission logo November 23, 2022 David Hsu Chief Executive Officer SolarMax Technology, Inc. 3080 12th Street Riverside, California 92507 Re:SolarMax Technology, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed October 28, 2022 File No. 333-266206 Dear David Hsu: We have reviewed your amended registration statement 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 by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe 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 these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 29, 2022 letter. Amendment No. 2 to Registration Statement on Form S-1 filed October 28, 2022 Our business is subject to the effects of inflation and supply chain issues, page 27 1.We note your response to prior comment 2, as well as disclosures indicating that you were not impacted by inflation or supply chain issues prior to mid-to-late 2021 but that you expect that these factors will continue to affect your ability to sell products, their price and your gross margin in both the United States and China. We also note that you have included disclosure that addresses how US operations have been affected by inflation during 2022. As requested in the comment, please revise the risk factor and MD&A to clearly discuss the extent to which your US operations have been affected by supply chain issues since mid-to-late 2021 to date.
FirstName LastNameDavid Hsu Comapany NameSolarMax Technology, Inc. November 23, 2022 Page 2 FirstName LastName David Hsu SolarMax Technology, Inc. November 23, 2022 Page 2 Management's Discussion and Analysis Inflation and Supply Chain Issues, page 73 2.We note your response to prior comment 5 but we are unable to locate the revised disclosure. As requested in the comment, please specify whether the principal factors contributing to the inflationary pressures and supply chain issues the company has experienced are known trends, events, and uncertainties that have materially impacted your results of operations or capital resources. Identify actions taken or planned, if any, to mitigate the impact of these factors. Finally, please discuss whether these factors materially affect your outlook or business goals.
You may contact Ameen Hamady at (202) 551-3891 or Jennifer Monick at (202) 551- 3295 if you have questions regarding the financial statements and related matters. Please contact Ronald Alper at (202) 551-3329 or Pamela Long at (202) 551-3765 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Asher Levitsky
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United States securities and exchange commission logo
November 23, 2022
David Hsu
Chief Executive Officer
SolarMax Technology, Inc.
3080 12th Street
Riverside, California 92507
Re:SolarMax Technology, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed October 28, 2022
File No. 333-266206
Dear David Hsu:
We have reviewed your amended registration statement 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 by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe 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 these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our August 29, 2022 letter.
Amendment No. 2 to Registration Statement on Form S-1 filed October 28, 2022
Our business is subject to the effects of inflation and supply chain issues, page 27
1.We note your response to prior comment 2, as well as disclosures indicating that you were
not impacted by inflation or supply chain issues prior to mid-to-late 2021 but that you
expect that these factors will continue to affect your ability to sell products, their price and
your gross margin in both the United States and China. We also note that you have
included disclosure that addresses how US operations have been affected by
inflation during 2022. As requested in the comment, please revise the risk factor and
MD&A to clearly discuss the extent to which your US operations have been affected by
supply chain issues since mid-to-late 2021 to date.
FirstName LastNameDavid Hsu
Comapany NameSolarMax Technology, Inc.
November 23, 2022 Page 2
FirstName LastName
David Hsu
SolarMax Technology, Inc.
November 23, 2022
Page 2
Management's Discussion and Analysis
Inflation and Supply Chain Issues, page 73
2.We note your response to prior comment 5 but we are unable to locate the revised
disclosure. As requested in the comment, please specify whether the principal factors
contributing to the inflationary pressures and supply chain issues the company has
experienced are known trends, events, and uncertainties that have materially impacted
your results of operations or capital resources. Identify actions taken or planned, if any, to
mitigate the impact of these factors. Finally, please discuss whether these factors
materially affect your outlook or business goals.
You may contact Ameen Hamady at (202) 551-3891 or Jennifer Monick at (202) 551-
3295 if you have questions regarding the financial statements and related matters. Please contact
Ronald Alper at (202) 551-3329 or Pamela Long at (202) 551-3765 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Asher Levitsky