SEC Comment Letter 0000000000-23-008454 to ACM Research, Inc. (ACMR) (CIK 0001680062) (ACMR)
ACM Research, Inc. (ACMR) (CIK 0001680062)
Date: Aug. 4, 2023 · CIK: 0001680062 · Accession: 0000000000-23-008454
AI Filing Summary & Sentiment
File numbers found in text: 001-38273
Letter
United States securities and exchange commission logo August 4, 2023 Mark McKechnie Chief Financial Officer ACM Research, Inc. 42307 Osgood Road, Suite I Fremont, CA 94539 Re:ACM Research, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 File No. 001-38273 Dear Mark McKechnie: We have limited our review of your filing to the submission and/or disclosures as required by Item 9C of Form 10-K 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. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2022 Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 142 1.We note your statement that you reviewed your stockholder register and certain public filings in connection with your required submission under paragraph (a). Please supplementally describe any additional materials that were reviewed and tell us whether you relied upon any legal opinions or third party certifications such as affidavits as the basis for your submission. 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.
FirstName LastNameMark McKechnie Comapany NameACM Research, Inc. August 4, 2023 Page 2 FirstName LastName Mark McKechnie ACM Research, Inc. August 4, 2023 Page 2 Please contact Austin Pattan at (202) 551-6756 or Jennifer Gowetski at (202) 551- 3401 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Michael Hedge
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United States securities and exchange commission logo
August 4, 2023
Mark McKechnie
Chief Financial Officer
ACM Research, Inc.
42307 Osgood Road, Suite I
Fremont, CA 94539
Re:ACM Research, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
File No. 001-38273
Dear Mark McKechnie:
We have limited our review of your filing to the submission and/or disclosures as
required by Item 9C of Form 10-K 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.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 142
1.We note your statement that you reviewed your stockholder register and certain public
filings in connection with your required submission under paragraph (a). Please
supplementally describe any additional materials that were reviewed and tell us whether
you relied upon any legal opinions or third party certifications such as affidavits as the
basis for your submission.
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.
FirstName LastNameMark McKechnie
Comapany NameACM Research, Inc.
August 4, 2023 Page 2
FirstName LastName
Mark McKechnie
ACM Research, Inc.
August 4, 2023
Page 2
Please contact Austin Pattan at (202) 551-6756 or Jennifer Gowetski at (202) 551-
3401 with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Michael Hedge