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May 14, 2020
Louis Giordimaina
Chief Executive Officer
Aerkomm Inc.
923 Incline Way #39
Incline Village, NV 89451
Re:Aerkomm Inc.
Registration Statement on Form S-1
Filed April 30, 2020
File No. 333-237942
Dear Mr. Giordimaina:
            We have limited our review of your registration statement to those issues we have
addressed in our 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.
Registration Statement on Form S-1
General
1.Please disclose the purpose of the transaction and the reasons that the company will only
be offering securities outside the United States and to non-U.S persons.  Also disclose the
countries in which the company intends to offer securities.  Finally, clarify whether the
company has any agreements or understandings with any potential investors for the
purchase of the securities in this offering.
2.Please tell us whether you intend to file the liquidity agreement with Invest Securities SA,
which authorizes Invest Securities to carry out market purchases and sales of shares of
your common stock on the Euronext Paris market.

 FirstName LastNameLouis Giordimaina
 Comapany NameAerkomm Inc.
 May 14, 2020 Page 2
 FirstName LastName
Louis Giordimaina
Aerkomm Inc.
May 14, 2020
Page 2
3.We note that your disclosure "does not take into account the impact" of the coronavirus
pandemic on your industry and markets and that the company is "unable to determine if it
will have a material impact on its operations." Given that your products are being
developed for the airline industry which has been severely impacted by the coronavirus
epidemic, please revise your disclosure accordingly.

            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 prior to the requested effective date of the registration
statement.
            Please contact Matthew Derby, Staff Attorney, at (202) 551-3334 or Jan Woo, Legal
Branch Chief, at (202) 551-3453 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Paul Levites