SecProbe.io

March 23, 2020
Gordon Roth
Chief Financial Officer
Roth CH Acquisition I Co.
888 San Clemente Drive, Suite 400
Newport Beach, CA 92660
Re:Roth CH Acquisition I Co.
Amendment No. 1 to
Registration Statement on Form S-1
Filed March 16, 2020
File No. 333-236852
Dear Mr. Roth:
            We have reviewed your registration statement 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 letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies 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 this comment, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1 filed March 16, 2020
Exhibits
1.We note that your amended and restated certificate of incorporation includes an exclusive
forum provision.  Please disclose this provision in your registration statement and include
risk factor disclosure.  In this regard, it appears that the exclusive forum provision does
not apply to the federal securities laws.  Please include whether the provision applies to
the federal securities laws in your disclosure.
            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 LastNameGordon Roth
 Comapany NameRoth CH Acquisition I Co.
 March 23, 2020 Page 2
 FirstName LastName
Gordon Roth
Roth CH Acquisition I Co.
March 23, 2020
Page 2
            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.
            You may contact Isaac Esquivel at 202-551-3395 or Shannon Menjivar at 202-551-3856
if you have questions regarding comments on the financial statements and related
matters.  Please contact Jonathan Burr at 202-551-5833 or Pamela Long at 202-551-3765 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction