SEC Comment Letter 0000000000-23-000814 to ACM Research, Inc. (ACMR) (CIK 0001680062) (ACMR)
ACM Research, Inc. (ACMR) (CIK 0001680062)
Date: Jan. 25, 2023 · CIK: 0001680062 · Accession: 0000000000-23-000814
AI Filing Summary & Sentiment
File numbers found in text: 001-38273
Letter
United States securities and exchange commission logo January 25, 2023 Mark McKechnie Chief Financial Officer, Executive Vice President and Treasurer ACM Research, Inc. 42307 Osgood Road, Suite I Fremont, California 94539 Re:ACM Research, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Form 10-Q for Fiscal Quarters Ended June 30, 2022 File No. 001-38273 Dear Mark McKechnie: We have reviewed your December 5, 2022 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 26, 2022 letter. Form 10-Q for the Fiscal Quarters Ended September 30, 2022 Item 2. Managements Discussion and Analysis of Financial Condition and Results of Operations, page 39 1.You state on page 14 of your Form 10-Q that in October, 2022 the U.S. Department of Commerce “enacted new rules aimed at restricting U.S. support for the PRC’s ability to manufacture advanced semiconductors." Please describe the material effects on your business of such new rules and provide related risk factor disclosure. You may contact Inessa Kessman, Senior Staff Accountant, at 202-551-3371 or Robert Littlepage, Accounting Branch Chief, at 202-551-3361 if you have any questions.
FirstName LastNameMark McKechnie Comapany NameACM Research, Inc. January 25, 2023 Page 2 FirstName LastName Mark McKechnie ACM Research, Inc. January 25, 2023 Page 2 Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
January 25, 2023
Mark McKechnie
Chief Financial Officer, Executive Vice President and Treasurer
ACM Research, Inc.
42307 Osgood Road, Suite I
Fremont, California 94539
Re:ACM Research, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Form 10-Q for Fiscal Quarters Ended June 30, 2022
File No. 001-38273
Dear Mark McKechnie:
We have reviewed your December 5, 2022 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
October 26, 2022 letter.
Form 10-Q for the Fiscal Quarters Ended September 30, 2022
Item 2. Managements Discussion and Analysis of Financial Condition and Results of Operations,
page 39
1.You state on page 14 of your Form 10-Q that in October, 2022 the U.S. Department of
Commerce “enacted new rules aimed at restricting U.S. support for the PRC’s ability to
manufacture advanced semiconductors." Please describe the material effects on your
business of such new rules and provide related risk factor disclosure.
You may contact Inessa Kessman, Senior Staff Accountant, at 202-551-3371 or Robert
Littlepage, Accounting Branch Chief, at 202-551-3361 if you have any questions.
FirstName LastNameMark McKechnie
Comapany NameACM Research, Inc.
January 25, 2023 Page 2
FirstName LastName
Mark McKechnie
ACM Research, Inc.
January 25, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Technology