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CORRESP
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DLA Piper LLP (US)

2525 East Camelback Road,
 Suite 1000

 Phoenix, Arizona 85016-4232

www.dlapiper.com

Steven D. Pidgeon

 Steven.Pidgeon@dlapiper.com
 T 480.606.5124
 F 480.606.5524

April 20, 2023

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Jeff Gordon

    Kevin Woody

    Jennifer Angelini

    Erin Purnell

 Re: Roth CH Acquisition IV Co

                                            Amendment No. 2 to Registration Statement on Form S-4

                                            Filed April 7, 2023

                                            File No. 333-269095

Ladies and Gentlemen:

On behalf of our client, Roth CH Acquisition IV Co. (“ROCG”
or the “Company”), we submit this letter setting forth the responses of the Company to the comments that were provided by
the staff (the “Staff”) of the Division of Corporation Finance of the United States Securities and Exchange Commission (the
 “Commission”) by your letter dated April 18, 2023 (the “Comment Letter”), regarding the above-referenced
filing (the “Registration Statement”). Concurrently with the filing of this letter, the Company is filing its Amendment No. 3
to Registration Statement on Form S-4 (the “Amended Registration Statement”), which includes changes to reflect responses
to the Staff’s comments and other updates.

We are authorized by the Company to provide the responses contained
in this letter on its behalf. For your convenience, the text of each comment of the Staff in the Comment Letter is included in italics
below and the Company’s responses appear below each comment. The references in the captions below correspond to the numbered paragraphs
of the Comment Letter.

Amendment No. 2 to Form S-4

General

1. Please revise disclosure relating to the
                                            non-redemption agreements and related payments to reconcile apparent inconsistencies, for
                                            example, on pages 115, 136, F-18, and F-22. Clarify which party entered the agreements,
                                            made or will make payments, and received or will receive reimbursement. Revise references
                                            to "certain initial stockholders," which does not appear to be a defined term,
                                            to specifically identify these parties. Revise disclosure in the summary section under the
                                            heading "The Sponsor and ROCG’s Directors and Executive Officers Have Financial
                                            Interests in the Business Combination," and add disclosure in the related party transactions
                                            section, as appropriate to reflect the foregoing payments and commitments.

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Company
Response: The Company respectfully acknowledges the Staff’s comment and respectfully advises the Staff that we have
updated the disclosure on pages xix, 9, 67, 122, 146, and 222 of the Amended Registration Statement to reflect the
requested disclosure.

2. We note your disclosure that, "In further recognition of Roth’s
                                            contributions, the Sponsors additionally intend to, following the Closing, transfer to Roth
                                            for no consideration up to a number of shares of the Combined Company’s common stock
                                            equal to two-thirds of the potential 200,000 Variable Shares which are not issued pursuant
                                            to the BCMA Termination Agreement." Please revise the reference to "Variable Shares,"
                                            which does not appear to be a defined term, and clarify that Roth is itself a sponsor, according
                                            to the definition on page v. Additionally revise disclosure within the related party
                                            transactions section related to Roth on page 260 to describe the amendment to the BCMA
                                            Termination Agreement and the intended transfer of shares from the other sponsors.

Company
Response: The Company respectfully acknowledges the Staff’s comment and respectfully advises the Staff that we have
updated the disclosure on pages 18, 290, and 291 of the Amended Registration Statement to reflect the requested disclosure.

Material U.S. Federal Income Tax Consequences, page 231

3. On page 231, you state that "This
                                            discussion is for general information only" and that shareholders are urged to consult
                                            their tax advisors as to the particular tax considerations of the business combination to
                                            them, including the applicability and effect of any U.S. federal laws. Investors are entitled
                                            to rely on your disclosure. Revise to eliminate these inappropriate disclaimers. You may
                                            recommend that investors consult their own advisors with respect to consequences of the transactions
                                            that could vary based on their particular circumstances. For guidance, refer to Section III.D.
                                            of Staff Legal Bulletin No. 19.

Company
Response: The Company respectfully acknowledges the Staff’s comment and respectfully advises the Staff that we have
updated the disclosure on page 251 of the Amended Registration Statement to reflect the requested disclosure.

Material Tax Consequences with respect to a Redemption of Public
Shares, page 232

4. We
                                            note you have included a "short-form" tax opinion as Exhibit 8.2 to the Registration
                                            Statement. Please revise this section to state clearly that the disclosure is the opinion
                                            of named counsel, and to ensure that the disclosure clearly identifies and articulates the
                                            opinion being rendered with respect to each material tax consequence being opined upon. For
                                            guidance, refer to Section III.B.2 of Staff Legal Bulletin 19.

Company
Response: The Company respectfully acknowledges the Staff’s comment and respectfully advises the Staff that we have
updated the disclosure on page 252 of the Amended Registration Statement to reflect the requested disclosure.

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The Company and its management acknowledge they are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff.

If you have any questions regarding the matters discussed above, please
telephone the outside counsel to the Company, Steven Pidgeon at (480) 606-5124 or via email at Steven.Pidgeon@us.dlapiper.com.

    Very truly yours,

    /s/ Steven Pidgeon

    Steven Pidgeon

    cc:
    Gordon Roth, Chief Financial Officer, Roth
    CH Acquisition IV Co.

    Colin J. Diamond, White & Case LLP

    Laura Katherine Mann, White & Case
    LLP

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