SecProbe.io

CORRESP
 1
 filename1.htm

 DATAVAULT AI INC.

 15268 NW Greenbrier Pkwy

 Beaverton, OR 97006

 September 19, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 100 F Street, NE

 Washington D.C. 20549

 RE:
 Datavault AI Inc.

 Registration Statement on Form S-3 filed on September 19, 2025

 File No. 333-290405

 Ladies and Gentlemen:

 In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will be declared effective at 5:30 p.m., Eastern Time, on September 23, 2025, or as soon thereafter as
is practicable.

 Sincerely,

 Datavault AI Inc .

 By:
 /s/ Nathaniel Bradley

 Nathaniel Bradley

 Chief Executive Officer

 cc:
 David E. Danovitch, Sullivan & Worcester LLP

 Aaron M. Schleicher, Sullivan & Worcester LLP

CORRESP
 1
 filename1.htm

 DATAVAULT AI INC.

 15268 NW Greenbrier Pkwy

 Beaverton, OR 97006

 September 10, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 100 F Street, NE

 Washington D.C. 20549

 RE:
 Datavault AI Inc.

 Registration Statement on Form S-3 filed on August 27, 2025

 File No. 333-289888

 Ladies and Gentlemen:

 In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will be declared effective at 5:00 p.m., Eastern Time, on September 12, 2025, or as soon thereafter as
is practicable.

 Sincerely,

 Datavault AI Inc .

 By:
 /s/ Nathaniel Bradley

 Nathaniel Bradley

 Chief Executive Officer

 cc:
 David E. Danovitch, Sullivan & Worcester LLP

 Aaron M. Schleicher, Sullivan & Worcester LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 4, 2025

Nathaniel Bradley
Chief Executive Officer
Datavault AI Inc.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006

 Re: Datavault AI Inc.
 Registration Statement on Form S-3
 Filed August 27, 2025
 File No. 333-289888
Dear Nathaniel Bradley:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Scott Anderegg at 202-551-3342 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: David E. Danovitch
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 4, 2025

Nathaniel Bradley
Chief Executive Officer
Datavault AI Inc.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006

 Re: Datavault AI Inc.
 Draft Registration Statement on Form S-3
 Submitted August 27, 2025
 CIK No. 000168149
Dear Nathaniel Bradley:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement and
non-public draft
submission on EDGAR at least two business days prior to the requested effective
date and
time. Please refer to Rules 460 and 461 regarding requests for acceleration. 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.

 Please contact Scott Anderegg at 202-551-3342 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: David E. Danovitch
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Datavault AI Inc.

 15268 NW Greenbrier Pkwy

 Beaverton, OR 97006

 July 9, 2025

 Via EDGAR

 Eranga Dias

 Division of Corporation Finance

 Office of Manufacturing

 100 F Street, NE

 Securities and Exchange Commission

 Washington, D.C. 20549

 Re:
 Datavault AI Inc.

 Draft Registration Statement on Form S-3

 Submitted May 9, 2025

 CIK No. 0001682149

 Ladies and Gentlemen:

 This correspondence responds to the comments received
from the staff of the Securities and Exchange Commission (the " Staff ") on May 28, 2025 regarding the above-mentioned
Draft Registration Statement on Form S-3 (the " Registration Statement ") by Datavault AI Inc. (the " Company ",
 " we ", " us " or " our "). For convenience, the Staff's comments are summarized
below in bold text, followed by our responses. We are concurrently filing with this letter the registration statement on Form S-3 (the
 " Registration Statement ").

 Draft Registration Statement on Form S-3

 General

 1.
 We note that you are registering the resale of up to 12,897,401 shares of "Additional Warrant Shares" that underlie "Additional Warrants" that will be issued at a future "Additional Closing" date. Because these "Additional Warrants" are not yet outstanding and will not be outstanding until the "Additional Closing" date, it does not appear appropriate at this time to register the resale of the associated common stock. Please revise your registration statement accordingly or provide your analysis as to why you are able to register the resale of these shares at this time. Refer generally to Securities Act Compliance Disclosure and Disclosure Interpretation 139.11.

 Response: In response to the Staff's
comment, we respectfully submit that the Additional Closing occurred on May 19, 2025 (the "Additional Closing Date") and the
Additional Warrants to purchase the Additional Warrant Shares were issued on the Additional Closing Date. The disclosure in the Registration
Statement has been revised accordingly.

 If you have any questions or comments regarding
the foregoing, please contact Aaron M. Schleicher, Esq. at (212) 660-3034 or aschleicher@sullivanlaw.com.

 Very truly yours,

 /s/ Nathaniel Bradley

 Nathaniel Bradley

 Chief Executive Officer

 cc:

 David E. Danovitch, Esq., Sullivan & Worcester LLP
 Aaron M. Schleicher, Esq., Sullivan & Worcester LLP

CORRESP
 1
 filename1.htm

 DATAVAULT AI INC.

 15268 NW Greenbrier Pkwy

 Beaverton, OR 97006

 July 9, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 100 F Street, NE

 Washington D.C. 20549

 RE:
 Datavault AI Inc.

 Registration Statement on Form S-3 filed on July 9, 2025

 File No. 333-288596

 Ladies and Gentlemen:

 In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will be declared effective at 5:30 p.m., Eastern Time, on July 11, 2025, or as soon thereafter as is practicable.

 Sincerely,

 Datavault AI Inc .

 By:
 /s/ Nathaniel Bradley

 Nathaniel Bradley

 Chief Executive Officer

 cc:
 David E. Danovitch, Sullivan & Worcester LLP

 Aaron M. Schleicher, Sullivan & Worcester LLP

CORRESP
 1
 filename1.htm

 DATAVAULT AI INC.

 15268 NW Greenbrier Pkwy

 Beaverton, OR 97006

 July 7, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 100 F Street, NE

 Washington D.C. 20549

 RE:
 Datavault AI Inc.

 Registration Statement on Form S-3 filed on July 7, 2025

 File No. 333-

 Ladies and Gentlemen:

 In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will be declared effective at 5:30 p.m., Eastern Time, on July 9, 2025, or as soon thereafter as is practicable.

 Sincerely,

 Datavault AI Inc .

 By:
 /s/ Nathaniel Bradley

 Nathaniel Bradley

 Chief Executive Officer

 cc:
 David E. Danovitch, Sullivan & Worcester LLP

 Aaron M. Schleicher, Sullivan & Worcester LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 28, 2025

Nathaniel Bradley
Chief Executive Officer
Datavault AI Inc.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006

 Re: Datavault AI Inc.
 Draft Registration Statement on Form S-3
 Submitted May 9, 2025
 CIK No. 0001682149
Dear Nathaniel Bradley:

 We have reviewed your draft registration statement and have the following
comment(s).

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-3 filed May 9, 2025
General

1. We note that you are registering the resale of up to 12,897,401 shares
of "Additional
 Warrant Shares" that underlie "Additional Warrants" that will be issued
at a future
 "Additional Closing" date. Because these "Additional Warrants" are not
yet
 outstanding and will not be outstanding until the "Additional Closing"
date, it does not
 appear appropriate at this time to register the resale of the associated
common stock.
 Please revise your registration statement accordingly or provide your
analysis as to
 why you are able to register the resale of these shares at this time.
Refer generally to
 Securities Act Compliance Disclosure and Disclosure Interpretation
139.11.
 May 28, 2025
Page 2

 Please contact Eranga Dias at 202-551-8107 or Jay Ingram at 202-551-3397
with any
other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Manufacturing
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 28, 2025

Nathaniel Bradley
Chief Executive Officer
Datavault AI Inc.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006

 Re: Datavault AI Inc.
 Draft Registration Statement on Form S-3
 Submitted April 25, 2025
 CIK No. 0001682149
Dear Nathaniel Bradley:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement at least
two business
days prior to the requested effective date and time. Please refer to Rules 460
and 461
regarding requests for acceleration. 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.

 Please contact Bradley Ecker at 202-551-4985 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

DATAVAULT AI INC.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

February 14, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    Datavault AI Inc. (f/k/a WiSA Technologies, Inc.)

    Registration Statement on Form S-3

    File No. 333-284657

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will be declared effective at 4:00 p.m., Eastern Time, on February 14, 2025, or as soon thereafter as
is practicable.

Sincerely,

    Datavault AI Inc.

    By:
    /s/ Nathaniel Bradley

    Nathaniel Bradley

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

WiSA Technologies, Inc.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

February 12, 2025

Via EDGAR

Erin Donahue

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Securities and Exchange Commission

Washington, D.C. 20549

    Re:
    WiSA Technologies, Inc.

    Registration Statement on Form S-3

    Filed February 3, 2025

    File No. 333-284657

Ladies and Gentlemen:

This correspondence responds to the verbal comments
received from the staff of the Securities and Exchange Commission (the “Staff”) regarding the above-mentioned Registration
Statement on Form S-3 (the “Registration Statement”) by WiSA Technologies, Inc. (the “Company”,
 “we”, “us” or “our”). For convenience, the Staff’s verbal comments are
summarized below in bold text, followed by our responses. We are concurrently filing with this letter Amendment No. 1 to the Registration
Statement (“Amendment No. 1”).

Registration Statement on Form S-3

General

    1.
    We note that your incorporation by reference section is missing the quarterly reports on Form 10-Q for the quarterly periods after December 31, 2023. Please file a pre-effective amendment to incorporate such quarterly reports by reference.

Response: In response to the Staff’s
comment, we have incorporated the quarterly reports on Form 10-Q by reference in Amendment No. 1.

If you have any questions or comments regarding
the foregoing, please contact Aaron M. Schleicher, Esq. at (212) 660-3034 or aschleicher@sullivanlaw.com.

Very truly yours,

    /s/ Nathaniel Bradley

    Nathaniel Bradley

    Chief Executive Officer

    cc:

    David E. Danovitch, Esq., Sullivan & Worcester LLP

    Aaron M. Schleicher, Esq., Sullivan & Worcester LLP

CORRESP
1
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WISA TECHNOLOGIES, INC.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

February 12, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    Registration Statement on Form S-3

    File No. 333-284657

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will be declared effective at 4:00 p.m., Eastern Time, on February 14, 2025, or as soon thereafter as
is practicable.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Nathaniel Bradley

    Nathaniel Bradley

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

February 6, 2025
Nathaniel Bradley
Chief Executive Officer
WISA TECHNOLOGIES, INC.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WISA TECHNOLOGIES, INC.
Registration Statement on Form S-3
Filed February 3, 2025
File No. 333-284657
Dear Nathaniel Bradley:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Erin Donahue at 202-551-6063 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
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WISA TECHNOLOGIES, INC.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

June 21, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    Registration Statement on Form S-1

    File No. 333-280238

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will be declared effective at 4:00 p.m., Eastern Time, on June 25, 2024, or as soon thereafter as is practicable.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    President and Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

United States securities and exchange commission logo
June 21, 2024
Brett Moyer
Chief Executive Officer
WISA TECHNOLOGIES, INC.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WISA TECHNOLOGIES, INC.
Registration Statement on Form S-1
Filed June 14, 2024
File No. 333-280238
Dear Brett Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Eranga Dias at 202-551-8107 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

 WiSA Technologies, Inc.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

April 16, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    Registration Statement on Form S-3

    File No. 333-278622

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended (the “Act”), WiSA Technologies, Inc. (the “Registrant”)
hereby requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate action to accelerate
the effective date of the above-referenced registration statement (the “Registration Statement”) so as to become effective
on Thursday, April 18, 2024, at 4:45 p.m. Eastern Time, or as soon thereafter as practicable.

The Registrant understands that the Commission
will consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that the
Registrant is aware of its responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed
resale of the securities specified in the Registration Statement by the selling stockholders named therein.

Once the Registration Statement is effective,
please orally confirm the event with our counsel, Sullivan & Worcester LLP, by calling David Danovitch at (212) 660-3060, or in his
absence, Aaron Schleicher at (212) 660-3034. We also respectfully request that copies of the written order from the Commission verifying
the effective date and time of the Registration Statement be sent to Mr. Danovitch via email at ddanovitch@sullivanlaw.com and to Mr.
Schleicher via email at aschleicher@sullivanlaw.com.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

United States securities and exchange commission logo
April 16, 2024
Brett Moyer
Chief Executive Officer
WISA TECHNOLOGIES, INC.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WISA TECHNOLOGIES, INC.
Registration Statement on Form S-3
Filed on April 11, 2024
File No. 333-278622
Dear Brett Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Bradley Ecker at 202-551-4985 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

Maxim Group LLC

300 Park Avenue, 16th Floor

New York, New York 10022

February 8, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    WISA Technologies, Inc. (the “Company”)

    Registration Statement on Form S-1 (File No. 333-276631)

Ladies and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission (the “Commission”)
under the Securities Act of 1933, as amended (the “Securities Act”), Maxim Group LLC, as exclusive placement
agent for the proposed offering, hereby joins the request of WISA Technologies, Inc. (the “Company”) that the
effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 9:00 a.m. Eastern
Time on Monday, February 12, 2024, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and
Regulations of the Commission under the Securities Act, please be advised that there will be distributed to each underwriter, dealer or
agent, who is reasonably anticipated to participate in the distribution of the securities in this offering, as many copies of the preliminary
prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned
is aware of its obligations under the provisions of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, including the delivery
requirements contained in such Rule, in connection with the above-referenced issue.

    Very truly yours,

    Maxim Group LLC

    By:
    /s/Clifford A. Teller

    Name:
     Clifford A. Teller

    Title:
     Co-President

    cc:
    Leslie Marlow, Esq.

Patrick J. Egan, Esq.

CORRESP
1
filename1.htm

WiSA Technologies, Inc.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

February 8, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    Registration Statement on Form S-1, as amended

    File No. 333-276631

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended (the “Act”), WiSA Technologies, Inc. (the “Registrant”)
hereby requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate action to accelerate
the effective date of the above-referenced registration statement (the “Registration Statement”) so as to become effective
on Monday, February 12, 2024, at 9:00 a.m. Eastern Time, or as soon thereafter as practicable.

The Registrant understands that the Commission
will consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that the
Registrant is aware of its responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed
sale of the securities specified in the Registration Statement by the Registrant.

Once the Registration Statement is effective,
please orally confirm the event with our counsel, Sullivan & Worcester LLP, by calling David Danovitch at (212) 660-3060, or in his
absence, Aaron Schleicher at (212) 660-3034. We also respectfully request that copies of the written order from the Commission verifying
the effective date and time of the Registration Statement be sent to Mr. Danovitch via email at ddanovitch@sullivanlaw.com and to Mr.
Schleicher via email at aschleicher@sullivanlaw.com.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

United States securities and exchange commission logo
January 24, 2024
Brett Moyer
Chief Executive Officer
WiSA Technologies, Inc.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WiSA Technologies, Inc.
Registration Statement on Form S-1
Filed January 19, 2024
File No. 333-276631
Dear Brett Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Jenny O'Shanick at 202-551-8005 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Aaron Schleicher

CORRESP
1
filename1.htm

WISA TECHNOLOGIES, INC.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

September 29, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

RE:
WiSA Technologies, Inc.

Registration Statement on Form S-1

 File No. 333-274331

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will be declared effective at 4:00 p.m., Eastern Time, on September 29, 2023, or as soon thereafter as
is practicable.

Sincerely,

WiSA Technologies, Inc.

By:
/s/ Brett Moyer

Brett Moyer

President and Chief Executive Officer

cc:
David E. Danovitch, Sullivan & Worcester LLP

Aaron M. Schleicher, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

Maxim Group LLC

300 Park Avenue, 16th Floor

New York, New York 10022

September 29, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Re:
WISA Technologies, Inc.

Registration Statement on Form S-1, as amended

 File No: 333-274331

Ladies and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission (the “Commission”)
under the Securities Act of 1933, as amended (the “Securities Act”), Maxim Group LLC, as exclusive placement
agent for the proposed offering, hereby joins the request of WISA Technologies, Inc. (the “Company”) that the
effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 4:00 p.m. Eastern
Time on Friday, September 29, 2023, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and
Regulations of the Commission under the Securities Act, please be advised that there will be distributed to each underwriter, dealer or
agent, who is reasonably anticipated to participate in the distribution of the securities in this offering, as many copies of the preliminary
prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned
is aware of its obligations under the provisions of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, including the delivery
requirements contained in such Rule, in connection with the above-referenced issue.

    Very
    truly yours,

    Maxim
    Group LLC

    By:
    /s/
    Clifford A. Teller

    Name:
    Clifford
    A. Teller

    Title:
    Co-President

cc:
Leslie Marlow, Esq., Blank Rome LLP

Patrick J. Egan, Esq., Blank Rome LLP

United States securities and exchange commission logo
September 8, 2023
Brett Moyer
Chief Executive Officer
WISA TECHNOLOGIES, INC.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WISA TECHNOLOGIES, INC.
Registration Statement on Form S-1
Filed on September 5, 2023
File No. 333-274331
Dear Brett Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Jenny O'Shanick at 202-551-8005 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Aaron Schleicher

United States securities and exchange commission logo
August 28, 2023
Brett Moyer
Chief Executive Officer
WISA TECHNOLOGIES, INC.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WISA TECHNOLOGIES, INC.
Registration Statement on Form S-1
Filed on August 22, 2023
File No. 333-274155
Dear Brett Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Jenny O'Shanick at 202-551-8005 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Aaron Schleicher

CORRESP
1
filename1.htm

WiSA Technologies, Inc.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

August 28, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    File No. 333-274155

    Registration Statement on Form S-1

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will become effective at 4:00 p.m. Eastern Time on August 30, 2023, or as soon thereafter as is practicable.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

United States securities and exchange commission logo
June 5, 2023
George Oliva
Chief Financial Officer
WiSA Technologies, Inc.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WiSA Technologies, Inc.
Registration Statement on Form S-1
Filed May 30, 2023
File No. 333-272278
Dear George Oliva:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Gregory Herbers at 202-551-8028 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Aaron M. Schleicher

CORRESP
1
filename1.htm

WiSA Technologies, Inc.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

June 5, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    File No. 333-272278

    Registration Statement on Form S-1

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will become effective at 4:00 p.m. Eastern Time on June 7, 2023, or as soon thereafter as is practicable.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Angela Gomes, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

WiSA Technologies, Inc.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

May 5, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    File No. 333-269777

    Registration Statement on Form S-1

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will become effective at 4:00 p.m. Eastern Time on May 9, 2023, or as soon thereafter as is practicable.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Angela Gomes, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

WiSA Technologies, Inc.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

May 1, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    File No. 333-271526

    Registration Statement on Form S-1

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will become effective at 4:00 p.m. Eastern Time on May 3, 2023, or as soon thereafter as is practicable.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Angela Gomes, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

United States securities and exchange commission logo
May 1, 2023
George Oliva
Chief Financial Officer
WISA TECHNOLOGIES, INC.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WISA TECHNOLOGIES, INC.
Registration Statement on Form S-1
Filed April 28, 2023
File No. 333-271526
Dear George Oliva:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Eranga Dias at 202-551-8107 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

United States securities and exchange commission logo
February 21, 2023
George Oliva
Chief Financial Officer
WISA TECHNOLOGIES, INC.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WISA TECHNOLOGIES, INC.
Registration Statement on Form S-1
Filed February 14, 2023
File No. 333-269777
Dear George Oliva:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Eranga Dias at 202-551-8107 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

WiSA Technologies, Inc.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

November 25, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    File No. 333-268085

    Registration Statement on Form S-1

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will become effective at 5:00 p.m. Eastern Time on November 29, 2022, or as soon thereafter as is practicable.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

WiSA Technologies, Inc.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

November 16, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    File No. 333-268231

    Registration Statement on Form S-3

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will become effective at 4:45 p.m. Eastern Time on November 18, 2022, or as soon thereafter as is practicable.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

United States securities and exchange commission logo
November 15, 2022
Brett Moyer
Chief Executive Officer
WiSA Technologies, Inc.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WiSA Technologies, Inc.
Registration Statement on Form S-3
Filed November 7, 2022
File No. 333-268231
Dear Brett Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Gregory Herbers at 202-551-8028 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       David E. Danovitch

United States securities and exchange commission logo
November 7, 2022
Brett Moyer
Chief Executive Officer
WiSA Technologies, Inc.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WiSA Technologies, Inc.
Registration Statement on Form S-1
Filed November 1, 2022
File No. 333-268085
Dear Brett Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Gregory Herbers at 202-551-8028 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:        David E. Danovitch

United States securities and exchange commission logo
September 9, 2022
George Olivia
Chief Financial Officer
WiSA Technologies, Inc.
15268 NW Greenbrier Pkwy
Beaverton, OR 97006
Re:WiSA Technologies, Inc.
Registration Statement on Form S-3
Filed September 1, 2022
File No. 333-267211
Dear Mr. Olivia:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Gregory Herbers at 202-551-8028 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       David E. Danovitch

CORRESP
1
filename1.htm

WiSA Technologies, Inc.

15268 NW Greenbrier Pkwy

Beaverton, OR 97006

September 9, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    WiSA Technologies, Inc.

    File No. 333-267211

    Registration Statement on Form S-3

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement
be accelerated so that the same will become effective at 4:00 p.m. Eastern Time on September 13, 2022, or as soon thereafter as is practicable.

Sincerely,

    WiSA Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

    Aaron M. Schleicher, Sullivan & Worcester LLP

United States securities and exchange commission logo
July 13, 2021
Brett Moyer
Chief Executive Officer
Summit Wireless Technologies, Inc.
6840 Via Del Oro, Ste. 280
San Jose, CA 95119
Re:Summit Wireless Technologies, Inc.
Registration Statement on Form S-3
Filed July 8, 2021
File No. 333-257776
Dear Mr. Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Jennifer Angelini at 202-551-3047 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Natalie S. Lederman

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro, Ste. 280

San Jose, CA 95119

July 12, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    Summit Wireless Technologies, Inc.

    File No. 333-257776

    Registration Statement on Form S-3

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended (the “Act”), Summit Wireless Technologies, Inc. (the “Registrant”)
hereby requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate action to accelerate
the effective date of the above-referenced registration statement (the “Registration Statement”) so as to become effective
on Wednesday, July 14, 2021, at 4:00 p.m. Eastern Time, or as soon thereafter as practicable.

The Registrant understands that the Commission
will consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that the
Registrant is aware of its responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed
resale of the securities specified in the Registration Statement by the selling stockholders named therein.

Once the Registration Statement is effective,
please orally confirm the event with our counsel, Sullivan & Worcester LLP, by calling David Danovitch at (212) 660-3060, or in his
absence, Natalie Lederman at (212) 660-3039. We also respectfully request that a copy of the written order from the Commission verifying
the effective date and time of the Registration Statement be sent to Mr. Danovitch via email at ddanovitch@sullivanlaw.com.

Sincerely,

    Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    George Oliva, Summit Wireless Technologies, Inc.

    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Natalie S. Lederman, Sullivan & Worcester LLP

United States securities and exchange commission logo
March 23, 2021
Brett Moyer
Chief Executive Officer
Summit Wireless Technologies, Inc.
6840 Via Del Oro
Suite 280
San Jose, CA 95119
Re:Summit Wireless Technologies, Inc.
Registration Statement on Form S-3
Filed March 19, 2021
File No. 333-254535
Dear Mr. Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Effie Simpson at (202) 551-3346 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       David Danovitch

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro, Ste. 280

San Jose, CA 95119

March 23, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    Summit Wireless Technologies, Inc.

    File No. 333-254535

    Registration Statement on Form S-3

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules
and Regulations under the Securities Act of 1933, as amended (the “Act”), Summit Wireless Technologies, Inc. (the “Registrant”)
hereby requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate action
to accelerate the effective date of the above-referenced registration statement (the “Registration Statement”) so as
to become effective on Thursday, March 25, 2021, at 4:30 p.m. Eastern Time, or as soon thereafter as practicable.

The Registrant understands that the Commission
will consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that
the Registrant is aware of its responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate
to the proposed resale of the securities specified in the Registration Statement by the selling stockholders named therein.

Once the Registration Statement is effective,
please orally confirm the event with our counsel, Sullivan & Worcester LLP, by calling David Danovitch at (212) 660-3060, or
in his absence, Michael DeDonato at (212) 660-3038. We also respectfully request that a copy of the written order from the Commission
verifying the effective date and time of the Registration Statement be sent to Mr. Danovitch via email at ddanovitch@sullivanlaw.com.

Sincerely,

    Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    George Oliva, Summit Wireless Technologies, Inc.

    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro, Ste. 280

San Jose, CA 95119

December 8, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    Summit Wireless Technologies, Inc.

    File No. 333-251177

    Registration Statement on Form S-3

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules
and Regulations under the Securities Act of 1933, as amended (the “Act”), Summit Wireless Technologies, Inc. (the “Registrant”)
hereby requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate action
to accelerate the effective date of the above-referenced registration statement (the “Registration Statement”) so as
to become effective on Thursday, December 10, 2020, at 5:00 p.m. Eastern Time, or as soon thereafter as practicable.

The Registrant understands that the Commission
will consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that
the Registrant is aware of its responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate
to the proposed resale of the securities specified in the Registration Statement by the selling stockholders named therein.

Once the Registration Statement is effective,
please orally confirm the event with our counsel, Sullivan & Worcester LLP, by calling David Danovitch at (212) 660-3060, or
in his absence, Michael DeDonato at (212) 660-3038. We also respectfully request that a copy of the written order from the Commission
verifying the effective date and time of the Registration Statement be sent to Mr. Danovitch via email at ddanovitch@sullivanlaw.com.

Sincerely,

    Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    George Oliva, Summit Wireless Technologies, Inc.

    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

United States securities and exchange commission logo
December 8, 2020
Brett Moyer
Chief Executive Officer
Summit Wireless Technologies, Inc.
6840 Via Del Oro, Suite 280
San Jose, CA 95119
Re:Summit Wireless Technologies, Inc.
Registration Statement on Form S-3
Filed December 7, 2020
File No. 333-251177
Dear Mr. Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       David E. Danovitch, Esq.

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro, Ste. 280

San Jose, CA 95119

July 21, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    Summit Wireless Technologies, Inc.

    File No. 333-239845

    Registration Statement on Form S-3

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules
and Regulations under the Securities Act of 1933, as amended (the “Act”), Summit Wireless Technologies, Inc. (the “Registrant”)
hereby requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate action
to accelerate the effective date of the above-referenced registration statement (the “Registration Statement”) so as
to become effective on Thursday, July 23, 2020, at 5:00 p.m. Eastern Time, or as soon thereafter as practicable.

The Registrant understands that the Commission
will consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that
the Registrant is aware of its responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate
to the proposed resale of the securities specified in the Registration Statement by the selling stockholders named therein.

Once the Registration Statement is effective,
please orally confirm the event with our counsel, Sullivan & Worcester LLP, by calling David Danovitch at (212) 660-3060, or
in his absence, Michael DeDonato at (212) 660-3038. We also respectfully request that a copy of the written order from the Commission
verifying the effective date and time of the Registration Statement be sent to Mr. Danovitch via email at ddanovitch@sullivanlaw.com.

Sincerely,

    Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    George Oliva, Summit Wireless Technologies, Inc.

    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro, Ste. 280

San Jose, CA 95119

July 20, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington D.C. 20549

    RE:
    Summit Wireless Technologies, Inc.

    File No. 333-239750

    Registration Statement on Form S-1

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules
and Regulations under the Securities Act of 1933, as amended (the “Act”), Summit Wireless Technologies, Inc. (the “Registrant”)
hereby requests that the United States Securities and Exchange Commission (the “Commission”) take appropriate action
to accelerate the effective date of the above-referenced registration statement (the “Registration Statement”) so as
to become effective on Wednesday, July 22, 2020, at 5:00 p.m. Eastern Time, or as soon thereafter as practicable.

The Registrant understands that the Commission
will consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that
the Registrant is aware of its responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate
to the proposed resale of the securities specified in the Registration Statement by the selling stockholders named therein.

Once the Registration Statement is effective,
please orally confirm the event with our counsel, Sullivan & Worcester LLP, by calling David Danovitch at (212) 660-3060, or
in his absence, Michael DeDonato at (212) 660-3038. We also respectfully request that a copy of the written order from the Commission
verifying the effective date and time of the Registration Statement be sent to Mr. Danovitch via email at ddanovitch@sullivanlaw.com.

Sincerely,

    Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    George Oliva, Summit Wireless Technologies, Inc.

    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

United States securities and exchange commission logo
July 16, 2020
Brett Moyer
Chief Executive Officer
Summit Wireless Technologies, Inc.
6840 Via Del Oro, Suite 280
San Jose, CA 95119
Re:Summit Wireless Technologies, Inc.
Registration Statement on Form S-3
Filed July 14, 2020
File No. 333-239845
Dear Mr. Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Daniel E.Danovitch, Esq.

United States securities and exchange commission logo
July 13, 2020
Brett Moyer
Chief Executive Officer
Summit Wireless Technologies, Inc.
6840 Via Del Oro, Suite 280
San Jose, CA 95119
Re:Summit Wireless Technologies, Inc.
Registration Statement on Form S-1
Filed July 8, 2020
File No. 333-239750
Dear Mr. Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Daniel E. Danovitch, Esq.

CORRESP
1
filename1.htm

Maxim Group LLC

405 Lexington Avenue

New York, New York 10174

April 17, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attention: Mr. Geoff Kruczek

    Re:
    Summit Wireless Technologies, Inc.

        Registration Statement on Form S-1

        File No: 333-237516

Ladies and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission (the “Commission”)
under the Securities Act of 1933, as amended (the “Securities Act”), Maxim Group LLC, as representative
of the underwriters, hereby joins the request of Summit Wireless Technologies, Inc. (the “Company”) that
the effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 5:00 p.m.
Eastern Time on Monday, April 20, 2020, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules
and Regulations of the Commission under the Securities Act, please be advised that there will be distributed to each underwriter
or dealer, who is reasonably anticipated to participate in the distribution of the securities in this offering, as many copies
of the preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The
undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by
participating dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act
of 1934, as amended, in connection with the above-referenced issue.

    Very truly yours,

    Maxim Group LLC

    By:
    /s/ Clifford A. Teller

    Name: Clifford A. Teller

    Title:   Head of Investment Banking,

            Executive Managing Director

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro, Ste. 280

San Jose, CA 95119

April 17, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

    Re:
    Summit Wireless Technologies, Inc.

    Registration Statement on Form S-1, as amended

    File No. 333-237516

    Request for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, Summit Wireless Technologies, Inc. (the “Registrant”)
hereby requests that the U.S. Securities and Exchange Commission accelerate the effective date of the above-referenced Registration
Statement on Form S-1, as amended (the “Registration Statement”), and declare the Registration Statement
effective as of 5:00 p.m. Eastern time, on April 20, 2020, or as soon thereafter as possible. This request for acceleration
is subject, however, to your receiving a telephone call prior to such time from our legal counsel, Sullivan & Worcester LLP
(“Sullivan”), confirming this request. The Registrant hereby authorizes each of David E. Danovitch and Michael
DeDonato of Sullivan to make such request on its behalf.

Once the Registration Statement has been
declared effective, please orally confirm that event with David E. Danovitch of Sullivan, counsel to the Registrant, at (212) 660-3060,
or in his absence, Michael DeDonato at (212) 660-3038.

*
*                     *

Sincerely,

    Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    George Oliva, Summit Wireless Technologies, Inc.

    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

April 6, 2020
Brett Moyer
Chief Executive Officer
Summit Wireless Technologies, Inc.
6840 Via Del Oro, Suite 280
San Jose, CA 95119
Re:Summit Wireless Technologies, Inc.
Registration Statement on Form S-1 filed April 1, 2020
File No. 333-237516
Dear Mr. Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Geoff Kruczek at (202) 551-3641 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       David Danovitch, Esq.

November 27, 2019
Brett Moyer
Chief Executive Officer
Summit Wireless Technologies, Inc.
6840 Via Del Oro Ste. 280
San Jose, CA 95119
Re:Summit Wireless Technologies, Inc.
Registration Statement on Form S-3
Filed November 20, 2019
File No. 333-234787
Dear Mr. Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Sergio Chinos, Staff Attorney, at (202) 551-7844 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro, Ste. 280

San Jose, CA 95119

November 27, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

    Attn:
    Thomas Jones

    Re:
    Summit Wireless Technologies, Inc.

    Registration Statement on Form S-3

    File No. 333-234787

    Request for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, Summit Wireless Technologies, Inc. (the “Registrant”)
hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) accelerate the effective
date of the above-referenced Registration Statement on Form S-3 (the “Registration Statement”) and declare
the Registration Statement effective as of 4:30 p.m. Eastern time, on December 2, 2019, or as soon thereafter as possible.
This request for acceleration is subject, however, to your receiving a telephone call prior to such time from our legal counsel,
Sullivan & Worcester LLP (“Sullivan”), confirming this request. The Registrant hereby authorizes each of
David E. Danovitch and Michael DeDonato of Sullivan to make such request on its behalf.

Once the Registration Statement has been
declared effective, please orally confirm that event with David E. Danovitch of Sullivan, counsel to the Registrant, at (212) 660-3060,
or in his absence, Michael DeDonato at (212) 660-3038.

*
*                     *

Sincerely,

    Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

September 5, 2019
Brett Moyer
Chief Executive Officer
Summit Wireless Technologies, Inc.
6840 Via Del Oro, Ste. 280
San Jose, CA 95119
Re:Summit Wireless Technologies, Inc.
Registration Statement on Form S-3
Filed August 23, 2019
File No. 333-233433
Dear Mr. Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Thomas Jones at 202-551-3602 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc:       David E. Danovitch, Esq.

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro, Ste. 280

San Jose, CA 95119

September 5, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

    Attn:
    Thomas Jones

    Re:
    Summit Wireless Technologies, Inc.

    Registration Statement on Form S-3

    File No. 333-233433

    Request for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, Summit Wireless Technologies, Inc. (the “Registrant”)
hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) accelerate the effective
date of the above-referenced Registration Statement on Form S-3 (the “Registration Statement”) and declare
the Registration Statement effective as of 4:00 p.m. Eastern time, on September 6, 2019, or as soon thereafter as possible.
This request for acceleration is subject, however, to your receiving a telephone call prior to such time from our legal counsel,
Sullivan & Worcester LLP (“Sullivan”), confirming this request. The Registrant hereby authorizes each of
David E. Danovitch and Michael DeDonato of Sullivan to make such request on its behalf.

Once the Registration Statement has been
declared effective, please orally confirm that event with David E. Danovitch of Sullivan, counsel to the Registrant, at (212) 660-3060,
or in his absence, Michael DeDonato at (212) 660-3038.

*
*                     *

Sincerely,

    Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

May 20, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Tim Buchmiller, Senior Attorney

    Re:
    Summit Wireless Technologies, Inc.

    Registration Statement on Form S-1

    File No. 333- 230952

    Request for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”), Alexander Capital,
L.P., as the sole underwriter, hereby joins in the request of Summit Wireless Technologies, Inc. for acceleration of the
effective date of the above-referenced Registration Statement on Form S-1 so that it becomes effective as of 5:00 p.m. Eastern
Time on Tuesday, May 21, 2019, or as soon thereafter as possible.

Pursuant to Rule 460 of the General
Rules and Regulations of the Securities Act, we wish to advise you that, through May 20, 2019, we distributed an aggregate
of approximately 300 copies of the preliminary prospectus of the Registration Statement, dated May 17, 2019, to potential investors.

The undersigned has and will comply with
the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page to Follow]

    Very truly yours,

    ALEXANDER CAPITAL, L.P.

    As the Sole Underwriter

    Named in the Underwriting Agreement

    By:
    /s/ Michele Misiti

    Name: Michelle Misiti

    Title: Director of Operations

[Signature Page to Underwriter’s
Acceleration Request]

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro, Ste. 280

San Jose, CA 95119

May 17, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

    Attn:
    Tim Buchmiller, Senior Attorney

    Re:
    Summit Wireless Technologies, Inc.

    Registration Statement on Form S-1

    File No. 333-230952

    Request for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, Summit Wireless Technologies, Inc. (the “Registrant”)
hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) accelerate the effective
date of the above-referenced Registration Statement on Form S-1 (as amended to date, the “Registration Statement”)
and declare the Registration Statement effective as of 5:00 p.m. Eastern time, on May 21, 2019, or as soon thereafter as
possible. This request for acceleration is subject, however, to your receiving a telephone call prior to such time from our legal
counsel, Sullivan & Worcester LLP (“Sullivan”), confirming this request. The Registrant hereby authorizes
each of David E. Danovitch and Michael DeDonato of Sullivan to make such request on its behalf.

Once the Registration Statement has been
declared effective, please orally confirm that event with David E. Danovitch of Sullivan, counsel to the Registrant, at (212) 660-3060,
or in his absence, Michael DeDonato at (212) 660-3038.

Under separate cover, you
will receive a letter today from the representative of the underwriters of the proposed offering joining in the
Registrant’s request for acceleration of the effectiveness of the Registration Statement.

*
*                     *

Sincerely,

    Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro Ste. 280

San Jose, CA
95119

May 13,
2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

    Attn:
    Tim Buchmiller, Senior Attorney

    Re:
    Summit Wireless Technologies, Inc.

    Registration Statement on Form S-1

    File No. 333-230952

    Withdrawal of Acceleration Request

Ladies
and Gentlemen:

Reference is made to our letter,
filed as correspondence via EDGAR on May 9, 2019, in which we requested the acceleration of the effective date of the above-referenced
Registration Statement, as amended, for Monday, May 13, 2019 at 5:00 p.m. Eastern Time, in accordance with Rule 461 under the Securities
Act of 1933, as amended. We are no longer requesting that such Registration Statement be declared effective at this time and we
hereby formally withdraw our request for acceleration of the effective date.

Sincerely,

Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

Summit Wireless Technologies, Inc.

6840 Via Del Oro, Ste. 280

San Jose, CA 95119

May 9, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

    Attn:
    Tim Buchmiller, Senior Attorney

    Re:
    Summit Wireless Technologies, Inc.

    Registration Statement on Form S-1

    File No. 333- 230952

    Request for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, Summit Wireless Technologies, Inc. (the “Registrant”)
hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) accelerate the effective
date of the above-referenced Registration Statement on Form S-1 (the “Registration Statement”) and declare
the Registration Statement effective as of 5:00 p.m. Eastern time, on May 13, 2019, or as soon thereafter as possible. This
request for acceleration is subject, however, to your receiving a telephone call prior to such time from our legal counsel, Sullivan
 & Worcester LLP (“Sullivan”), confirming this request. The Registrant hereby authorizes each of David E. Danovitch
and Michael DeDonato of Sullivan to make such request on its behalf.

Once the Registration Statement has been
declared effective, please orally confirm that event with David E. Danovitch of Sullivan, counsel to the Registrant, at (212) 660-3060,
or in his absence, Michael DeDonato at (212) 660-3038.

Under separate cover, you will receive
today a letter from the representative of the underwriters of the proposed offering joining in the Registrant’s request for
acceleration of the effectiveness of the Registration Statement.

*
*                     *

Sincerely,

    Summit Wireless Technologies, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    Gary Williams, Summit Wireless Technologies, Inc.

    David E. Danovitch, Sullivan & Worcester LLP

    Michael DeDonato, Sullivan & Worcester LLP

CORRESP
1
filename1.htm

May 9, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: 	Tim Buchmiller, Senior Attorney

 Re: Summit Wireless Technologies, Inc.

Registration Statement on Form S-1

File No. 333- 230952

Request for Acceleration of Effective
Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”), Alexander Capital,
L.P., as the representative of the several underwriters, hereby joins in the request of Summit Wireless Technologies, Inc.
for acceleration of the effective date of the above-referenced Registration Statement on Form S-1 so that it becomes effective
as of 5:00 p.m. Eastern Time on Monday May 13, 2019, or as soon thereafter as possible.

Pursuant to Rule 460 of the General
Rules and Regulations of the Securities Act, we, acting on behalf of the several underwriters, wish to advise you that, through
May 9, 2019, we distributed an aggregate of approximately 500 copies of the Preliminary Prospectus, dated April 18, 2019, to potential
investors.

The undersigned has and will comply with the requirements of
Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page to Follow]

    Very truly yours,

    ALEXANDER CAPITAL, L.P.

    As Representative of the Several Underwriters

    Named in the Underwriting Agreement

    By:
    /s/ Michele Misiti

    Name: Michelle Misiti

    Title: Director of Operations

[Signature Page to Underwriters’
Acceleration Request]

April 24, 2019
Brett Moyer
Chief Executive Officer
Summit Wireless Technologies, Inc.
6840 Via Del Oro, Ste. 280
San Jose, CA 95119
Re:Summit Wireless Technologies, Inc.
Registration Statement on Form S-1
Filed April 19, 2019
File No. 333-230952
Dear Mr. Moyer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Tim Buchmiller, staff attorney, at (202) 551-3635 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc:       David E. Danovitch, Esq.

CORRESP
1
filename1.htm

July 25, 2018

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Attn: Amanda Ravitz, Assistant Director

 Kevin J. Kuhar, Accounting Branch
Chief

Caleb French, Staff Attorney

Tim Buchmiller, Senior Attorney

 Re: Summit Semiconductor, Inc.

Registration Statement on Form S-1

File No. 333- 224267

Request for Acceleration of Effective
Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”), Alexander Capital,
L.P., as the representative of the several underwriters, hereby joins in the request of Summit Semiconductor, Inc. for acceleration
of the effective date of the above-referenced Registration Statement on Form S-1, as amended, so that it becomes effective
as of 5:30 p.m. Eastern Time on Wednesday, July 25, 2018, or as soon thereafter as possible.

Pursuant to Rule 460 of the General
Rules and Regulations of the Securities Act, we, acting on behalf of the several underwriters, wish to advise you that, through
July 25, 2018, we distributed an aggregate of approximately 500 copies of the Preliminary Prospectus, dated July 25, 2018, to potential
investors.

The undersigned has and will comply with the requirements of
Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page to Follow]

    Very truly yours,

    ALEXANDER CAPITAL, L.P.

    As Representative of the Several Underwriters

    Named in the Underwriting Agreement

    By:
    /s/ Michele Misiti

    Name: Michelle Misiti

    Title: Director of Operations

[Signature Page to Underwriters’
Acceleration Request]

CORRESP
1
filename1.htm

Summit Semiconductor, Inc.

6840 Via Del Oro Ste. 280

San Jose, CA 95119

July 25, 2018

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

    Attn:
    Amanda Ravitz, Assistant Director

    Kevin J. Kuhar, Accounting Branch Chief

    Caleb French, Staff Attorney

    Tim Buchmiller, Senior Attorney

    Re:
    Summit Semiconductor, Inc.

    Registration Statement on Form S-1

    File No. 333- 224267

    Request for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, Summit Semiconductor, Inc. (the “Registrant”)
hereby requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date
of the above-referenced Registration Statement on Form S-1 (as amended to date, the “Registration Statement”)
and declare the Registration Statement effective as of 5:30 p.m. Eastern time, on July 25, 2018, or as soon thereafter as
possible. This request for acceleration is subject, however, to your receiving a telephone call prior to such time from our legal
counsel, Robinson Brog Leinwand Greene Genovese & Gluck P.C. (“Robinson Brog”), confirming this request. The Registrant
hereby authorizes each of David E. Danovitch, Zachary Blumenthal, and Michael DeDonato of Robinson Brog to make such request on
its behalf.

Once the Registration Statement has been
declared effective, please orally confirm that event with David E. Danovitch, of Robinson Brog, counsel to the Registrant, at (212)
603-6391, or in his absence, Zachary Blumenthal at (212) 603-0497 or Michael DeDonato at (212) 603-6394.

Under separate cover, you will receive
today a letter from the representative of the underwriters of the proposed offering joining in the Company’s request for
acceleration of the effectiveness of the Registration Statement.

*
*
*

Sincerely,

    Summit Semiconductor, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    Gary Williams, Summit Semiconductor, Inc.

    David E. Danovitch, Robinson Brog Leinwand Greene Genovese & Gluck P.C.

    Zachary Blumenthal, Robinson Brog Leinwand Greene Genovese & Gluck P.C.

    Michael DeDonato, Robinson Brog Leinwand Greene Genovese & Gluck P.C.

CORRESP
1
filename1.htm

Summit Semiconductor, Inc.

6840 Via Del Oro Ste. 280

San
Jose, CA 95119

July 25,
2018

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

    Attn:
    Amanda Ravitz, Assistant Director

    Kevin J. Kuhar, Accounting Branch Chief

    Caleb French, Staff Attorney

    Tim Buchmiller, Senior Attorney

    Re:
    Summit Semiconductor, Inc.

    Registration Statement on Form S-1

    File No. 333- 224267

    Withdrawal of Acceleration Request

Ladies
and Gentlemen:

Reference is made to our letter,
filed as correspondence via EDGAR on July 25, 2018, in which we requested the acceleration of the effective date of the above-referenced
Registration Statement, as amended, for Tuesday, July 24, 2018 at 5:15 p.m. Eastern Time, in accordance with Rule 461 under the
Securities Act of 1933, as amended. We are no longer requesting that such Registration Statement be declared effective at this
time and we hereby formally withdraw our request for acceleration of the effective date.

Sincerely,

Summit Semiconductor, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    Gary Williams, Summit Semiconductor, Inc.

    David E. Danovitch, Robinson Brog Leinwand Greene Genovese & Gluck P.C.

    Zachary Blumenthal, Robinson Brog Leinwand Greene Genovese & Gluck P.C.

    Michael DeDonato, Robinson Brog Leinwand Greene Genovese & Gluck P.C.

CORRESP
1
filename1.htm

Summit Semiconductor, Inc.

6840 Via Del Oro Ste. 280

San Jose, CA 95119

July 25, 2018

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

    Attn:
    Amanda Ravitz, Assistant Director

    Kevin J. Kuhar, Accounting Branch Chief

    Caleb French, Staff Attorney

    Tim Buchmiller, Senior Attorney

    Re:
    Summit Semiconductor, Inc.

    Registration Statement on Form S-1

    File No. 333- 224267

    Request for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, Summit Semiconductor, Inc. (the “Registrant”)
hereby requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date
of the above-referenced Registration Statement on Form S-1 (as amended to date, the “Registration Statement”)
and declare the Registration Statement effective as of 5:15 p.m. Eastern time, on July 24, 2018, or as soon thereafter as
possible. This request for acceleration is subject, however, to your receiving a telephone call prior to such time from our legal
counsel, Robinson Brog Leinwand Greene Genovese & Gluck P.C. (“Robinson Brog”), confirming this request. The Registrant
hereby authorizes each of David E. Danovitch, Zachary Blumenthal, and Michael DeDonato of Robinson Brog to make such request on
its behalf.

Once the Registration Statement has been
declared effective, please orally confirm that event with David E. Danovitch, of Robinson Brog, counsel to the Registrant, at (212)
603-6391, or in his absence, Zachary Blumenthal at (212) 603-0497 or Michael DeDonato at (212) 603-6394.

Under separate cover, you will receive
today a letter from the representative of the underwriters of the proposed offering joining in the Company’s request for
acceleration of the effectiveness of the Registration Statement.

*
*
*

Sincerely,

    Summit Semiconductor, Inc.

    By:
    /s/ Brett Moyer

    Brett Moyer

    Chief Executive Officer

    cc:
    Gary Williams, Summit Semiconductor, Inc.

    David E. Danovitch, Robinson Brog Leinwand Greene Genovese & Gluck P.C.

    Zachary Blumenthal, Robinson Brog Leinwand Greene Genovese & Gluck P.C.

    Michael DeDonato, Robinson Brog Leinwand Greene Genovese & Gluck P.C.

CORRESP
1
filename1.htm

July 23, 2018

Amanda Ravitz

Assistant Director

Office of Electronics and Machinery

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

    Re:
    Summit Semiconductor, Inc.

    Amendment No. 5 to Registration Statement on Form S-1 (the “Registration Statement”)

    Filed July 6, 2018

    File No. 333-224267

Dear Ms. Ravitz:

This letter responds to the Staff’s
comment letter dated July 13, 2018, relating to the above-captioned Registration Statement. For your convenience, we have restated
the Staff’s comments and have provided our responses below such comments.

Prospectus Cover

    1.
    We note your revised disclosure indicates that you will not consummate your offering until Nasdaq approves your listing application. We also note you continue to disclose that no arrangements have been made to place funds received in the offering in escrow or a similar account pending closing. Since the initial closing of your offering will be contingent on Nasdaq approval, please revise the disclosure throughout your filing so that it is consistent with Exchange Act Rule 15c2-4. Also, disclose what will happen to investor funds if you terminate the offering; ensure your disclosed actions will comply with Exchange Act Rule 10b-9.

We have revised the disclosure
throughout our filing accordingly.

    2.
    Given your disclosure in the last risk factor on page 21, if there is a known minimum dollar amount you will need to raise in order to obtain Nasdaq approval, please disclose that minimum dollar amount.

We have revised the disclosure
on page 21 and throughout our filing accordingly.

If you have any questions regarding our responses, please contact
David E. Danovitch at 212-603-6300 or ded@robinsonbrog.com.

    Sincerely,

    /s/ Brett Moyer

    Chief Executive Officer

Mail Stop 3030
July 13, 2018

Via E -mail
Brett Moyer
Chief Executive Officer
Summit Semiconductor, Inc.
6840 Via Del Oro Ste. 280
San Jose, CA 95119

Re: Summit Semiconductor, Inc.
Amendment No. 5 to Registration Statement on Form S -1
Filed July 6, 2018
 File No. 333 -224267

Dear Mr. Moyer :

We have reviewed your amended registration statement  and have the following
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 no t 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.

Prospectus Cover

1. We note your revised disclosure indicates that you will not consummate your offering
until Nasdaq approves your listing application.  We also note you continue to disclose
that no arrangements have been made to place funds received in the offering in escr ow or
a similar account pending closing.  Since the initial closing of your offering will be
contingent on Nasdaq approval, please revise the disclosure throughout your filing so that
it is consistent with Exchange Act Rule 15c2 -4.  Also, disclose what wil l happen to
investor funds if you terminate the offering; ensure your disclosed actions will comply
with Exchange Act Rule 10b -9.

Brett Moyer
Summit Semiconductor, Inc.
July 13 , 2018
Page 2

 2. Given your disclosure in the last risk factor on page 21, if there is a known minimum
dollar amount you will need to raise in order to obtain Nasdaq approval, please disclose
that minimum dollar amount.

Please contact Caleb French  at (202) 551 -6947 or Tim Buchmiller, Senior Attorney,  at
(202) 551 -3635 with any questions.

Sincerely,

 /s/ Kevin J. Kuhar

 Kevin J. Kuhar
Accounting Branch Chief
Office of Electronics and Machinery

cc: David E. Danovitch, Esq.
Robinson Brog Leinwand Greene Genovese & Gluck, P.C.

CORRESP
1
filename1.htm

July 6, 2018

Amanda Ravitz

Assistant Director

Office of Electronics and Machinery

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

    Re:
    Summit Semiconductor, Inc.

    Amendment No. 4 to Registration Statement on Form
S-1 (the “Registration Statement”)

    Filed July 2, 2018

    File No. 333-224267

Dear Ms. Ravitz:

This letter responds to the Staff’s
comment letter dated July 5, 2018, relating to the above-captioned Registration Statement. For your convenience, we have restated
the Staff’s comments and have provided our responses below such comments.

Exhibit 5.1

 1. We note that this exhibit refers to stock that will
be sold in a resale transaction; however, your prospectus does not describe a resale offering. Please file an opinion that addresses
the offering registered and the prospectus included in your registration statement.

We have revised the first paragraph
of the exhibit accordingly.

 2. We note the first sentence of the second paragraph.
Your legality opinion may not limit the universe of documents considered in rendering the opinion. Please file an opinion that
does not contain such limitations.

We have revised the first sentence
of the second paragraph of the exhibit accordingly.

 3. Given that the registration statement registers
the offering of common stock, please tell us the purpose of the fifth paragraph. It is unclear why it is appropriate to render
an opinion on a common stock offering “subject to” the items noted in this paragraph.

We have revised the exhibit
by deleting this paragraph.

 4. Your legality opinion may not limit who can rely
on the opinion. Please file an opinion without the limitation found in the first sentence of the second page.

We have revised the exhibit
to delete such limitation.

If you have any questions regarding our responses, please contact
David E. Danovitch at 212-603-6300 or ded@robinsonbrog.com.

    Sincerely,

    /s/ Brett Moyer

    Chief Executive Officer

Mail Stop 3030
July 5 , 2018

Via E -mail
Brett Moyer
Chief Executive Officer
Summit Semiconductor, Inc.
6840 Via Del Oro Ste. 280
San Jose, CA 95119

Re: Summit Semiconductor, Inc.
Amendment No. 4 to Registration Statement on Form S -1
Filed July 2, 2018
 File No. 333 -224267

Dear Mr. Moyer :

We have reviewed your amended registration statement  and have the following
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 no t 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.

Exhibit 5.1

1. We note that this exhibit refers to stock that will be sold in a resale transaction; however,
your prospectus does not describe a resale offering.  Please file an opinion that addresses
the offering registered and the prospectus included in your registrati on statement.

2. We note the first sentence of the second paragraph.  Your legality opinion may not limit
the universe of documents considered in rendering the opinion.  Please file an opinion
that does not contain such limitations.

Brett Moyer
Summit Semiconductor, Inc.
July 5 , 2018
Page 2

 3. Given that the registr ation statement registers the offering of common stock, please tell us
the purpose of the fifth paragraph.  It is unclear why it is appropriate to render an opinion
on a common stock offering “subject to” the items noted in this paragraph.

4. Your legality  opinion may not limit who can rely on the opinion.  Please file an opinion
without the limitation found in the first sentence of the second page.

Please contact Caleb French  at (202) 551 -6947 or me at (202) 551 -3528 with any
questions.

Sincerely,

 /s/ Amanda Ravitz

 Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: David E. Danovitch, Esq.
Robinson Brog Leinwand Greene Genovese & Gluck, P.C.

CORRESP
1
filename1.htm

July 2, 2018

Amanda Ravitz

Assistant Director

Office of Electronics and Machinery

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

    Re:
    Summit Semiconductor, Inc.

Amendment No. 3 to Registration Statement on Form
S-1 (the “Registration Statement”)

Filed June 22, 2018

File No. 333-224267

Dear Ms. Ravitz:

This letter responds to the Staff’s
comment letter dated June 27, 2018, relating to the above-captioned Registration Statement. For your convenience, we have restated
the Staff’s comment and have provided our response below such comment.

Prospectus Summary, page 2

 1. We note your revised disclosure on page 17 indicating
you are in default under disclosed indebtedness. Please apply comment 3 in our letter dated May 23, 2018 to your current registration
statement. Specifically, given your disclosed default, please revise your prospectus summary to highlight, if true, that creditors
can claim proceeds of this offering in absence of a waiver. Also, ensure your revised summary disclosure clarifies if any of these
creditors are related persons as defined in Regulation S-K Item 404.

We have revised the disclosure
in the prospectus summary section accordingly.

If you have any questions regarding our responses, please contact
David E. Danovitch at 212-603-6300 or ded@robinsonbrog.com.

    Sincerely,

    /s/ Brett Moyer

    Chief Executive Officer

Mail Stop 3030
June 2 7, 2018

Via E -mail
Brett Moyer
Chief Executive Officer
Summit Semiconductor, Inc.
6840 Via Del Oro Ste. 280
San Jose, CA 95119

Re: Summit Semiconductor, Inc.
Amendment No. 3 to Registration Statement on Form S -1
Filed June 22, 2018
 File No. 333 -224267

Dear Mr. Moyer :

We have reviewed your amended registration statement  and have the following
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.

Prospectus Summary, page 2

1. We note your revised disclosure on page 17 indicating you are in default under disclosed
indebtedness.  Please apply comment 3 in our letter dated May 23, 2018 to y our current
registration statement.  Specifically, given your disclosed default, please revise your
prospectus summary to highlight, if true, that creditors can claim proceeds of this offering
in absence of a waiver.  Also, ensure your revised summary disc losure clarifies if any of
these creditors are related persons as defined in Regulation S -K Item 404.

Brett Moyer
Summit Semiconductor, Inc.
June 2 7, 2018
Page 2

 Please contact Caleb French  at (202) 551 -6947 or me at (202) 551 -3528 with any
questions.

Sincerely,

 /s/ A manda Ravitz

 Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: David E. Danovitch, Esq.
Robinson Brog Leinwand Greene Genovese & Gluck, P.C.

CORRESP
1
filename1.htm

June 22, 2018

Amanda Ravitz

Assistant Director

Office of Electronics and Machinery

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

 Re: Summit Semiconductor,
Inc.

Amendment
No. 2 to Registration Statement on Form S-1 (the “Registration Statement”)

Filed
May 31, 2018

File
No. 333-224267

Dear Ms. Ravitz:

This letter responds
to the Staff’s comment letter dated June 5, 2018, relating to the above-captioned Registration Statement. For your convenience,
we have restated the Staff’s comment and have provided our response below such comment.

Our
preliminary review of your registration statement indicates that it fails in numerous material respects to comply with the requirements
of the Securities Act of 1933, the rules and regulations under that Act, and the requirements of the form. In particular, your
filing must be amended to present updated financial statements required by Rule 8-08 of Regulation S-X. Further, your Management’s
Discussion and Analysis section must be amended to address the periods required to be included by Regulation S-X. Refer to Item
303(b) of Regulation S-K. We will not perform a detailed examination of the registration statement and we will not issue comments.
We suggest that you consider filing a substantive amendment to correct the deficiencies.

If
you were to request acceleration of the effective date of the registration statement in its present form, we would likely recommend
that the Commission deny your request.

The Registration Statement has been amended in accordance
with the Staff's comment, including to present updated financial statements through the period ended March 31, 2018 as required
by Rule 8-08 of Regulation S-X and updated disclosure in the Management’s Discussion and Analysis section of the Registration
Statement to address the periods required to be included by Regulation S-X.

If you have any questions regarding our responses, please contact
David E. Danovitch at 212-603-6300 or ded@robinsonbrog.com.

    Sincerely,

    /s/ Brett Moyer

    Chief Executive Officer

Mail Stop 3030
June 5, 2018

Via E -mail
Brett Moyer
Chief Executive Officer
Summit Semiconductor, Inc.
6840 Via Del Oro Ste. 280
San Jose, CA 95119

Re: Summit Semiconductor, Inc.
 Amendment No. 2 to Registration Statement on Form S-1
 Filed  May 31, 2018
 File No.  333-224267

Dear Mr. Moyer :

Our preliminary review of your registration statement indicates that it fails in numerous
material respects to comply with the requirements of the Securities Act of 1933, the rules and
regulations under that Act, and the requirements of the form.   In particular, your filing must be
amended to present updated financial statements required by Rule 8 -08 of Regulation S -X.
Further, your Management’s  Discussion and Analysis section must be amended to address the
periods required to be included by Regulation S -X.  Refer to Item 303(b) of Regulation S -K.  We
will not perform a detailed examination of the registration statement and we will not issue
comm ents.  We suggest that you consider filing a substantive amendment to correct the deficiencies.

If you were to request acceleration of the effective date of the registration statement in its
present form, we would likely recommend that the Commission d eny your request.

Sincerely,

 /s/ Amanda Ravitz

 Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: David E. Danovitch, Esq.
 Robinson Brog Leinwand Greene Genovese & Gluck, P.C.

CORRESP
1
filename1.htm

May 31, 2018

Amanda Ravitz

Assistant Director

Office of Electronics and Machinery

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

    Re:
    Summit Semiconductor, Inc.

Amendment No. 1 to Registration
Statement on Form S-1 (“Amendment No. 1”)

Filed May 7, 2018

File No. 333-224267

Dear Ms. Ravitz:

This letter responds to the Staff’s
comment letter dated May 23, 2018, relating to the above-captioned registration statement. For your convenience, we have restated
the Staff’s comments and have provided our responses below such comments.

Fee Table

    1.
    We note your response to prior comment 1. However, it remains unclear why the row reflecting the common stock underlying the underwriters’ warrant contains a symbol instead of a dollar amount. Please tell us what this symbol means. Does it indicate you will fill in the amount of securities offered to the underwriters before effectiveness? Also, ensure you have filled in all required information before effectiveness; we note, for example, the number of shares offered to the underwriters in footnote 1 to your prospectus cover page and the offering price of the securities.

We have revised the fee table accordingly to insert dollar symbols and amounts in the rows reflecting the proposed maximum aggregate offering price and registration fee amount for each of the common stock underlying the underwriters' warrant and the total securities being registered. We have also revised footnote 1 of the table on the prospectus cover page accordingly.  We will ensure that we have filled in all required information for such tables prior to requesting effectiveness.

Risk Factors, page 10

    2.
    We note that you filed a free writing prospectus on May 11, 2018. Tell us how you believe you met the filing and delivery conditions in Rule 433(b)(2)(i) regarding this free writing prospectus, given that the prospectus you have on file does not appear to meet the requirements of Section 10 of the Securities Act because it omits the volume of shares offered, the offering price of the shares and related information regarding your use of proceeds and dilution. If your use of the free writing prospectus exposes you to material risks, such as those relating to potential Section 5 violations, add appropriate risk factor disclosure addressing those risks.

While we believe our use of the free writing prospectus
filed on May 11, 2018 met the applicable guidelines and was permissible, we have added a risk factor related to the contingent
liability if the use of such free writing prospectus were to be challenged as a violation of Section 5 of the Securities Act. In
addition, we intend to re-circulate a preliminary prospectus that contains the volume or amount of shares being offered reflected
throughout the preliminary prospectus and a revised free writing prospectus to each recipient of the free writing prospectus.

Prospectus Summary, page 2

    3.
    We note your added disclosure on page 17 indicating that you are in default under disclosed indebtedness. Please revise your summary to highlight, if true, that creditors can claim proceeds of this offering in the absence of a waiver. Also, if any of these creditors are related persons as defined in Regulation S-K Item 404, ensure that your revised summary discloses the related nature of the creditors.

As we are no longer in default under the indebtedness
disclosed in Amendment No. 1, we have revised the disclosure on page 17 accordingly.

Use of Proceeds, page 27

    4.
    We note your response to prior comment 2 and your added disclosure that you intend to use proceeds from this offering to repay debt. Ensure that your table reflects the priority of uses as described in the text following the table. Also, revise to provide all information required by Instruction 4 to Regulation S-K Item 504.

We have revised the disclosure accordingly.

If you have any questions regarding our responses, please contact
David E. Danovitch at 212-603-6300 or ded@robinsonbrog.com.

    Sincerely,

    /s/ Brett Moyer

    Chief Executive Officer

Mail Stop 3030
May 23, 2018

Via E -mail
Brett Moyer
Chief Executive Officer
Summit Semiconductor, Inc.
6840 Via Del Oro Ste. 280
San Jose, CA 95119

Re: Summit Semiconductor, Inc.
Amendment No. 1 to Re gistration Statement on Form S -1
Filed May 7, 2018
  File No. 333 -224267

Dear Mr. Moyer:

We have reviewed your amended registration statement  and have the following
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 no t 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.   Unless  we note
otherwise , our references to prior comments are to comments in our April 30, 2018  letter .

Fee Table

1. We note your response to prior comment 1.  However, it remains unclear why the row
reflecting the common stock underlying the underwriters’ warrant contains a  symbol
instead of a dollar amount.  Please tell us what this symbol means.  Does it indicate you
will fill in the amount of securities offered to the underwriters before effectiveness?
Also, ensure you have filled in all required information before effec tiveness; we note, for
example, the number of shares offered to the underwriters in footnote 1 to your
prospectus cover page  and the offering price of the securities .

Brett Moyer
Summit Semiconductor, Inc.
May 23, 2018
Page 2

 Risk Factors, page 10

2. We note that you filed a free writing prospectus on May 11, 201 8.  Tell us how you
believe you met the filing and delivery conditions in Rule 433(b)(2)(i) regarding this free
writing prospectus, given that the prospectus you have on file does not appear to meet the
requirements of Section 10 of the Securities Act beca use it omits the volume of shares
offered, the offering price of the shares and related information regarding your use of
proceeds and dilution.  If your use of the free writing prospectus exposes you to material
risks,  such as those relating to potential Section 5 violations,  add appropriate risk factor
disclosure addressing those risks.

Prospectus Summary, page 2

3. We note your added disclosure on page 17 indicating that you are in default under
disclosed indebtedness.  Please revise your summary to highlight, if true, that creditors
can claim proceeds of this offering in the absence of a waiver.  Also, if any of the se
creditors are related persons as defined in Regulation S -K Item 404, ensure that your
revised summary discloses the related nature of the creditors.

Use of Proceeds, page 27

4. We note your response to prior comment 2 and your added disclosure that you  intend to
use proceeds from this offering to repay debt.  Ensure that your table reflects the priority
of uses as described in the text following the table.  Also, revise to provide all
information required by Instruction 4 to Regulation S -K Item 504.

You may contact Gary Newberry  at (202) 551 -3761 or Lynn Dicker, Senior Accountant,
at (202) 551 -3616 if you have questions regarding comments on the financial statements and
related matters.  Please contact Caleb French  at (202) 551 -6947 or me at (202) 551 -3528 with
any other questions.

Sincerely,

 /s/ Amanda Ravitz

 Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: David E. Danovitch, Esq.
 Robinson Brog Leinwand Greene Genovese & Gluck, P.C.

CORRESP
1
filename1.htm

May
7, 2018

Amanda Ravitz

Assistant Director

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

    Re:
    Summit Semiconductor, LLC

Registration Statement on Form
S-1

Submitted April 13, 2018

File No. 333-224267

Dear Ms. Ravitz:

This letter responds to the Staff’s comment
letter dated April 30, 2018, relating to the above-captioned registration statement. For your convenience, we have restated the
Staff’s comments and have provided the Company’s response below such comments.

Fee Table

    1.
    We note your revisions to the fee table; however, the table does not appear to reflect all securities offered.  Ensure that this table reflects the amount of securities offered to the underwriters as part of this offering.

We have revised the fee table accordingly to reflect all
securities offered.

Use of Proceeds, page 27

    2.
    We note your revised disclosure in response to prior comment 6.  Given the best efforts nature of this offering, expand your revised disclosure to indicate your currently intended priority for uses if you sell substantially less than half of your offered shares

We have revised the disclosure accordingly.

Capitalization, page 29

    3.
    We note from the cover page that your offering is being conducted on a best efforts basis with no firm commitment from an underwriter and that there is no minimum number of shares that must be sold.  We also note the pro forma as adjusted amounts you intend to include in a future amendment.  Please revise the capitalization table to remove all adjustments and disclosures relating to the receipt and application of any proceeds from this offering, or tell us why you believe such adjustments are factually supportable.  Refer to Note 2 of Article 8-01 and Article 11-02(b)(6) of Regulation S-X.

We have revised the disclosure accordingly.

Certain Relationships and Related Persons Transactions, page
59

    4.
    We note your revisions to this section.  Given the timeframe specified in Instruction 1 to Item 404 of Regulation S-K, it is unclear why you removed disclosure about transactions occurring in 2015.  Also, your disclosure in the section titled “Significant Unitholders/Stockholders” beginning on page 61 should indicate the names of the related persons whose transactions you disclose.  Please revise or advise.

We have revised the disclosure accordingly.

Principal Stockholders, page 64

    5.
    We note your response to prior comment 3.  However, given your revisions throughout indicating this is a best efforts offering on your behalf, it remains unclear why the table on page 65 suggests that your existing shareholders are offering shares.  Please revise to remove these columns or clarify the purpose of those columns.

We have revised the disclosure accordingly.

Underwriting, page 74

    6.
    We note your revisions in response to prior comment 2.  Given that your revised disclosure indicates this is a best efforts offering and the underwriters are under no obligation to sell any minimum number of shares, it is unclear why the added table on page 74 suggests the underwriters will be obligated to purchase a number of shares.  Please revise your disclosure in this section to clearly indicate the offering’s nature and the nature of the underwriters’ obligation to purchase shares from you.

We have revised the disclosure accordingly.

Item 17. Undertakings, page II-5

    7.
    We note your revisions in response to prior comment 2 adding undertakings.  Please tell us why you include the undertakings for an offering under Rule 430C, as indicated by the section numbered (4).  Also, if you intend to omit prospectus information in reliance on Rule 430A, please note the undertakings required by Regulation S-K Item 512(i).

We have revised the disclosure accordingly.

If you have any questions regarding our responses, please contact
David E. Danovitch at 212-603-6300 or ded@robinsonbrog.com.

    Sincerely,

    /s/ Brett Moyer

    Chief Executive Officer

Mail Stop 3030
April 30, 2018

Via E -mail
Brett Moyer
Chief Executive Officer
Summit Semiconductor, Inc.
6840 Via Del Oro Ste. 280
San Jose, CA 95119

Re: Summit Semiconductor, Inc.
Registration Statement on Form S-1
Filed April 13, 2018
  File No. 333-224267

Dear Mr. Moyer :

We have reviewed your registration statement  and have the following 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.   Unless we note
otherwise, our references to prior comments are to comments in our February 28, 2018 letter.

Fee Table

1. We note your revisions to the fee table; however, the table does not app ear to reflect all
securities offered.  Ensure that this table reflects the amount of securities offered to the
underwriters as part of this offering.

Use of Proceeds, page 27

2. We note your revised disclosure in response to prior comment 6.  Given the b est efforts
nature of this offering, expand your revised disclosure to indicate your currently intended
priority for uses if you sell substantially less than half of your offered shares.

Brett Moyer
Summit Semiconductor, Inc.
April 30, 2018
Page 2

 Capitalization, page 29

3. We note from the cover page that your off ering is being conducted on a best efforts basis
with no firm commitment from an underwriter and that there is no minimum number of
shares that must be sold.  We also note the pro forma as adjusted  amounts you intend to
include in a future amendment.   Please revise the capitalization table to remove all
adjustments and disclosures relating to the receipt and application of any proceeds from
this offering, or tell us why you believe such adjustments are factually supportable.  Refer
to Note 2 of Article 8 -01 and Article 11 -02(b)(6) of Regulation S -X.

Certain Relationships and Related Persons Transactions, page 59

4. We note your revisions to this section.  Given the timeframe specified in Instruction 1 to
Item 404 of Regulation S -K, it is unclear why you remov ed disclosure about transactions
occurring in 2015.  Also, your disclosure in the section titled “Significant
Unitholders/Stockholders” beginning on page 61 should indicate the names of the related
persons whose transactions you disclose.  Please revise or  advise.

Principal Stockholders, page 64

5. We note your response to prior comment 3.  However, given your revisions throughout
indicating this is a best efforts offering on your behalf, it remains unclear why the table
on page 65 suggests that your existing shareholders are offering shares.  Please revise to
remove these columns or clarify the purpose of those columns.

Underwriting, page 74

6. We note your revisions in response to prior comment 2.  Given that your revised
disclosure indicates this is a best efforts offering and the underwriters are under no
obligation to sell any minimum number of shares, it is unclear why the added table on
page 74 suggests the underwriters will be obligated to purchase a number of shares.
Please revise your disclosu re in this section to clearly indicate the offering’s nature and
the nature of the underwriters’ obligation to purchase shares from you.

Item 17.  Undertakings, page II -5

7. We note your revisions in response to prior comment 2 adding undertakings.  Pleas e tell
us why you include the undertakings for an offering under Rule 430C, as indicated by the
section numbered (4).  Also, if you intend to omit prospectus information in reliance on
Rule 430A, please note the undertakings required by Regulation S -K Item  512(i).

Brett Moyer
Summit Semiconductor, Inc.
April 30, 2018
Page 3

 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.

You may contact Gary Newberry  at (202) 551 -3761  or Lynn Dicker, Senior Accountant,
at (202) 551 -3616  if you have questions regarding comments on the financial statements and
related matters.  Please contact Caleb French  at (202) 551 -6947  or me at (202) 551 -3528  with
any other questions.

Sincerely,

 /s/ Amanda Ravitz

 Amanda Ravitz
 Assistant Director
Office of Electronics and Machinery

cc: David E. Danovitch, Esq.
 Robinson Brog Leinwand Greene Genovese & Gluck, P.C.

Mail Stop 3030
February 28 , 2018

Via E -mail
Brett Moyer
Chief Executive Officer
Summit Semiconductor, Inc.
6840 Via Del Oro Ste. 280
San Jose, CA 95119

Re: Summit Semiconductor, Inc.
Amendment No. 1 to
Draft Registration Statement on Form S -1
Submitted February 6, 2018
  CIK No. 0001682149

Dear Mr. Moyer :

We have reviewed your amended draft registration statement  and have the following
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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments app ly to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

Prospectus Cover Page

1. We note your response to prior comment 3; however, it appears no such revisions on the
prospectus cover page have bee n made.  Please revise accordingly.

2. We note your response to prior comment 4 that this is a best efforts offering.  Revise your
disclosure here to provide all information required by Item 501(b)(3) and (8) of
Regulation S -K, and ensure your disclosure th roughout reflects the type of best efforts
underwriting.  Also, revise your undertakings in Part II to include the undertakings
required by Item 512(a).

Brett Moyer
Summit Semiconductor, Inc.
February 28, 2018
Page 2

 3. In this regard, given your response to prior comment 4, the purpose of the column
“Number of Shares Of fered” in your principal stockholders table on page 60 remains
unclear.  Please revise or advise.

4. We note your response to prior comment 5.  Here and throughout your prospectus were
you disclose your plan to apply to list your shares on the NASDAQ, revis e the disclosure
to state that there is no assurance that your shares will be approved for listing.  Also, tell
us whether you plan to apply to list your shares before the closing of this offering.

Overview, page 1

5. We note your response to prior comment  7.  Please relocate the disclosure to a part of
your prospectus in which you can more fully discuss your relationship with your
significant customers.

Our Technology, page 2

6. Please reconcile your response to prior comment 8 with your Use of Proceeds di sclosure
on page 26.  In addition, note that your Use of Proceeds disclosure should take into
account the best efforts underwriting of this offering.

WiSA Association, page 2

7. Please revise your disclosure here to include the disclosure in your response t o prior
comment 9 that WiSA Certified products are required to use Summit modules in order to
meet the standards set by the association and clarify, if true, that the technology you
distribute includes the software modules your members purchase from you.

Risk Factors, page 10

8. We note your response to prior comment 14.  Please add appropriate risk factor
disclosure.

Certain Relationships and Related Person Transactions, page 54

9. We note yo ur response to prior comment 13; however, we note  the standard you outline
in your introductory paragraph to this section.  Please revise this language and disclose
additional  transactions , if any,  that meet the standard in Item 404(d)  of Regulation S -K.

Passive Market Making, page 70

10. Note that Rule 1 03 of Regulation M does not apply to best efforts offerings.  Please
revise your disclosure accordingly.

Brett Moyer
Summit Semiconductor, Inc.
February 28, 2018
Page 3

 You may contact Gary Newberry  at (202) 551 -3761 or Lynn Dicker, Senior Accountant,
at (202) 551 -3616 if you have questions regarding comments on the f inancial statements and
related matters.  Please contact Heather Percival  at (202) 551 -3498 or me at (202) 551 -3528 with
any other questions.

Sincerely,

 /s/ Amanda Ravitz

Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: David E. Danovitch
  Robinson Brog Leinwand Greene Genovese and Gluck, P.C.

CORRESP
1
filename1.htm

February 5, 2018

Amanda Ravitz

Assistant Director

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

 Re: Summit Semiconductor, LLC

Draft Registration Statement
on Form S-1

Submitted October 31, 2017

CIK No. 0001682149

Dear Ms. Ravitz:

This letter responds to the Staff’s
comment letter dated November 27, 2017 relating to the above-captioned registration statement. For your convenience, we have restated
the Staff’s comments and have provided the Company’s response below such comments.

General

 1. Your disclosure should readily highlight for investors the unique features presented by an offering
of LLC units. Since ownership of LLC units provides investors with certain rights, opportunities and risks not present in typical
common stock equity offerings, please revise to discuss the basic features of the LLC unit offering in the summary, risk factors
and elsewhere as appropriate. Consider for example discussing (1) the fact that the origin of rights and obligations is typically
contractual in nature, rather than statutory, and provides management with broad flexibility in setting and amending rights, (2)
whether liquid markets develop at the same level as common equity offerings, and (3) implications of pass through tax treatment
and possible related distributions, if any.

We converted to a corporation, effective December
31, 2017, and as such, revised the disclosures throughout the registration statement accordingly.

 2. Please supplementally provide us with copies of all written
communications, as defined in Rule 405 under the Securities Act, that you, or anyone
authorized to do so on your behalf, present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.

As of the date of this response,
we have not utilized any written communications nor has it yet authorized any other person to do so on its behalf to present to
potential investors in reliance on Section 5(d).

Prospectus Cover Page

 3. Revise to include the underwriters warrant.

We have revised applicable disclosure
on the cover page accordingly.

 4. Your cover page disclosure implies a firm commitment offering of securities. Disclosure on pages
54 and 59 suggests that selling shareholders will also offer securities, and that the underwriting is being conducted on a “best
efforts” basis. Please revise your cover page or other disclosure for consistency.

The cover page has been revised
accordingly to clarify that the underwriting is being conducted on a “best efforts.”

 5. We note your intent to list on the NASDAQ. Unless your shares have already been approved for
a listing, revise to reflect the anticipatory nature of this statement.

We have revised the disclosure
throughout the draft registration statement accordingly to reflect the anticipatory nature of the disclosure.

Overview, page 1

 6. We note several references to your web address and the web addresses of third parties throughout
your disclosure. Please consult Release 33-7856 (footnote 41 and the related text) (April 28, 2000) regarding your obligations
when using internet addresses in your submission, and revise as appropriate.

We
have advised the printer not to hyperlink any URL addresses and further, for each URL address we added disclosure that the
information contained in or accessible through such website is not part of the prospectus or the registration statement of which
the prospectus forms a part, and is intended for informational purposes only, consistent with afore-referenced obligations pursuant
to Release 33-7856.

 7. Tell us the basis upon which you chose the customers to highlight in your disclosure; avoid
including customers based solely on name recognition.

The customers highlighted in
our overview and throughout our registration statement were done so because: (a) they represent our most significant customers
in terms of engineering coordination, significant projects, and existing order and revenue; and (b) they represent the most aggressive
segment of our industry in driving the use of wireless audio. The fact that they represent well-known brand names is purely coincidental.

Our Technology, page 2

 8. We note your disclosure regarding your software development. Revise to disclose what steps remain
before commercialization of this new technology, expected capital requirements and anticipated sources of those funds.

A prototype version of our software
technology has been demonstrated to select customers (pursuant to confidentiality agreements) at the recent 2018 Consumer Electronics
Show in Las Vegas, NV. We plan to use approximately $3M from the IPO to productize our intellectual property through continued
invention and robust testing.

We have revised the disclosure
accordingly.

WiSA Association, page 2

 9. Given that your subsidiary is responsible for certifying products are WiSA interoperable and
comply with various tests, please highlight your relationship with the certifying body when you highlight your products’
WiSA compliance.

For products with a WiSA Certification,
WiSA also creates, maintains and manages testing criteria and specifications for all products to be listed, marketed and sold.
WiSA Certification is an industrywide “stamp of approval” certifying that a product is interoperable with other WiSA
Certified products and has passed several high-performance tests ensuring low levels of latency, tight channel synchronization.
As owners of WiSA, LLC, Summit certifies all WiSA products. Summit does not actually sell any WiSA-certified products; however,
it does distribute the technology to enable products to meet the WiSA certification test specifications. Currently, WiSA Certified
products are required to use Summit modules in order to meet the standards set by the association. As a result, WiSA members purchase
modules from us in order to build their products.

We have revised the disclosure
accordingly.

Dilution,
page 27

 10. Revise the table on page 28 to disclose how the numbers and percentages may change upon exercise
of outstanding warrants.

We have added disclosure that assuming
an initial public offering price of $XX per share (the midpoint
of the range), warrants could be exercised which would result in the increase
to the pro forma as adjusted net tangible book value by approximately
$XX per share. We have also added disclosure with respect to the amount of warrants that are outstanding.

Liquidity and Capital Resources, page
32

 11. Revise to clarify whether you will need to raise the amounts disclosed in the fourth paragraph
after conducting this offering.

We revised the disclosure to
state that assuming we raise at least a net of $7 million in the IPO, we will use the proceeds to pay for the amounts described
in that paragraph. As such, we do not plan on raising additional capital to finance those items. In the event that we fail to raise
such amount, we will need to raise additional capital.

What Makes Summit Unique, page 36

 12. Please provide additional data about your products’ low latency, synchronicity and high
audio resolution. In an appropriate section, provide empirical data, if available, comparing your technology to competitive technologies
in terms of the attributes you highlight as your competitive strengths and weaknesses.

We have added the additional information accordingly.

Certain Relationships and Related Person Transactions, page
49

 13. Please revise to discuss transactions involving the amounts that are specified in Regulation
S-K Item 404(d)(1) or advise.

Jonathan Gazdak is a related
party since he is the managing director of Alexander Capital, L.P.

(who is an underwriter for the
IPO) and is on our board of directors. We have added disclosure that Alexander Capital, L.P. is acting as an underwriter for the
IPO, and as such, is receiving underwriter discounts and commissions.

Preferred Membership Interest Units, page 55

 14. Revise to disclose the portion of your authorized capital that your board may designate as preferred
membership interest units. Also, provide us your analysis of whether there is a material risk that your board may designate and
issue preferred units with rights and preferences that would materially impact this offering’s investors.

Given the conversion from a limited liability company
to a stock corporation and the addition of blank check preferred, we have revised the disclosure to reflect the new capital structure.
We have also added disclosure that any current outstanding preferred stock will be converted to common stock upon completion of
the IPO and any future issuances of preferred stock will dilute the investors in the IPO.

Choice of Forum, page 56

 15. Revise to clarify your disclosure in this section. If your organizing documents contain provisions
limiting the forum where unitholders can bring actions against you, please add appropriate risk factor disclosure.

We have revised the disclosure
accordingly and added an appropriate risk factor.

Material U.S. Federal Income Tax Considerations,
page 58

 16. Tell us whether you intend to file a tax opinion and if not, explain the basis for not doing
so.

We respectfully believe that
Form S-1 does not require the inclusion of a section addressing the tax consequences of acquiring, owning or disposing of an issuer’s
securities. Notwithstanding this, the Company determined to include a general summary of the material United States federal income
tax consequences in the Registration Statement in order to provide additional information to investors. However, such section of
the Registration Statement does not include any representations as to the tax consequences to investors in the offering; rather,
it provides general disclosure related to the tax treatment of acquiring, holding and disposing of the Company’s securities.
Item 601(b)(8) of Regulation S-K requires that a tax opinion be filed as an exhibit to a registration statement only if a representation
as to tax consequences is set forth in the registration statement. The tax section included in the Registration Statement does
not provide any representations as to tax consequences. Accordingly, we respectfully believe that no tax opinion is required.

Consolidated Financial Statements

Consolidated Balance Sheets, page F-2

 17. Please disclose the liquidation preference of your preferred stock, as described on page F-21,
on the face of the Consolidated Balance Sheet. Refer to ASC 505-10-50-4.

We have disclosed the liquidation
preference of the preferred stock on the face of the Consolidated Balance Sheet on page F-3.

Notes to Consolidated Financial Statements

Note 7 – Preferred Units and Members’
Deficit, page F-21

 18. Please explain to us why the liquidation preference requires the preferred units to be presented
outside of members’ deficit. Refer to Rule 5-02.27 of Regulation S-X.

The preferred units are presented
outside of the members’ deficit because in the event of a change in control of the Company, the holders of the preferred
units would be entitled to receive a distribution of the legally available assets of the Company. In accordance with Rule 5-02.27(a)(3)
of Regulation S-X, a change in control of a company is considered an event that is not solely within the control of such company.

Common Units, page F-21

 19. Please tell us the maximum number of common units that are authorized, and how this differs
from common units that are issued and outstanding.

Subsequent to the conversion
from a limited liability company to a corporation, the Company now has 200,000,000 shares of common stock authorized, and 20,000,000
shares of blank check preferred stock authorized. Prior to the conversion, there were 5,122,221 units authorized and outstanding,
as disclosed on the face of the consolidated balance sheet on page F-3.

Warrants for Common Units, page F-22

 20. Please tell us why the warrants issued with the Series C and D Convertible Notes are recognized
as liabilities. Include the terms of these warrants and the authoritative guidance as part of your response.

The warrants issued with the
Series C and Series D Convertible Notes are recognized as liabilities as they contain price protection rights which qualify as
a variable number of shares at settlement in accordance with ASC 480-10-25-14. If the Company issues units at a price per share
less than the exercise price then in effect or without consideration, then the exercise price of the warrants will be adjusted
as specified in the warrant agreement. We have revised the disclosures on page F-24 to include such information.

Note 8 – Commitments and Contingencies

Other Commitments, page F-24

 21. We note your discussion of the Carve-Out Plan on pages F-21 and F-24. Please revise the filing
to disclose how any amounts payable under this plan will be recognized for accounting purposes.

We have revised the disclosure
on page F-26 to disclose that any amounts payable under this plan will be recognized as compensation in the consolidated statement
of operations during the period the Company becomes obligated to make such payments.

Item 15. Recent Sales of Unregistered
Securities, page II-2

 22. Revise to provide the disclosure required by Regulation S-K Item 701.

We have added the required disclosure.

Item 16. Exhibits and Financial Statement Schedules, page
II-3

 23. Revise to disclose the exhibits you have filed and intend to file with the registration statement.

We revised the exhibit table accordingly.

If you have any questions regarding our responses, please contact
David E. Danovitch at 212-603-6300 or ded@robinsonbrog.com.

    Sincerely,

    /s/ Brett Moyer

    Chief Executive Officer

Mail Stop 3030
November 27 , 2017

Via E -mail
Brett Moyer
Chief Executive Officer
Summit Semiconductor, LLC
20575 NW Von Neumann Drive, Suite 100
Beaverton, OR 97006

Re: Summit Semiconductor, LLC
Draft Registration Statement on Form S -1
Submitted October 31, 2017
  CIK No. 0001682149

Dear Mr. Moyer :

We have reviewed your draft registration statement  and have the following 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 providing the requested information and either submitting
an amended draft registration statement or  publicly  filing your registration statement on
EDGAR.  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 the information you provide in response to these  comments  and your
amende d draft registration statement or filed registration statement,  we may have  additional
comments.

General

1. Your disclosure should readily highlight for investors the unique features presented by an
offering of LLC units.  Since ownership of LLC units pro vides investors with certain
rights, opportunities and risks not present in typical common stock equity offerings,
please revise to discuss the basic features of the LLC unit offering in the summary, risk
factors and elsewhere as appropriate.  Consider for  example discussing (1) the fact that
the origin of rights and obligations is typically contractual in nature, rather than statutory,
and provides management with broad flexibility in setting and amending rights, (2)
whether liquid markets develop at the s ame level as common equity offerings, and (3)
implications of pass through tax treatment and possible related distributions, if any.

Brett Moyer
Summit Semiconductor, LLC
November 27 , 2017
Page 2

2. Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Ac t, that you, or anyone authorized to do so on your
behalf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.

Prospectus Cover Page

3. Revise to include the underwrite rs warrant.

4. Your cover page disclosure implies a firm commitment offering of securities.  Disclosure
on pages 54 and 59 suggests that selling shareholders will also offer securities, and that
the underwriting is being conducted on a “best efforts” basis.  Please revise your cover
page or other disclosure for consistency.

5. We note your intent to list on the NASDAQ.  Unless your shares have already been
approved for a listing, revise to reflect the anticipatory nature of this statement.

Overview, page 1

6. We note several references to your web address and the web addresses of third parties
throughout your disclosure.  Please consult Release 33 -7856 (footnote 41 and the related
text) (April 28, 2000) regarding your obligations when using internet addresses i n your
submission, and revise as appropriate.

7. Tell us the basis upon which you chose the customers to highlight in your disclosure;
avoid including customers based solely on name recognition.

Our Technology, page 2

8. We note your disclosure regarding your software development.  Revise to disclose what
steps remain before commercialization of this new technology, expected capital
requirements and anticipated sources of those funds.

WiSA Association, page 2

9. Given tha t your subsidiary is responsible for certifying products are WiSA interoperable
and comply with various tests, please highlight your relationship with the certifying body
when you highlight your products’ WiSA compliance.

Brett Moyer
Summit Semiconductor, LLC
November 27 , 2017
Page 3

 Dilution, page 27

10. Revise the t able on page 28 to disclose how the numbers and percentages may change
upon exercise of outstanding warrants.

Liquidity and Capital Resources, page 32

11. Revise to clarify whether you will need to raise the amounts disclosed in the fourth
paragraph after conducting this offering.

What Makes Summit Unique, page 36

12. Please provide additional data about your products’ low latency, synchronicity and high
audio resolution.  In an appropriate section, provide empirical data, if available,
comparing your technology to competitive technologies in terms of the attributes you
highlight as your competitive strengths and weaknesses.

Certain Relationships and Related Person Transactions, page 49

13. Please revise to discuss transactions involving the amounts that are specified in
Regulation S -K Item 404(d)(1) or advise.

Prefer red Membership Interest Units, page 55

14. Revise to disclose the portion of your authorized capital that your board may designate as
preferred membership interest units.  Also, provide us your analysis of whether there is a
material risk that your board may designate and issue preferred units with rights and
preferences that would materially impact this offering’s investors.

Choice of Forum, page 56

15. Revise to clarify your disclosure in this section.  If your organizing documents contain
provisions limitin g the fora where unitholders can bring actions against you, please add
appropriate risk factor disclosure.

Material U.S. Federal Income Tax Considerations, page 58

16. Tell us whether you intend to file a tax opinion and if not, explain the basis for not d oing
so.

Brett Moyer
Summit Semiconductor, LLC
November 27 , 2017
Page 4

 Consolidated Financial Statements

Consolidated Balance Sheets, page F -2

17. Please disclose the liquidation preference of your preferred stock, as described on page F -
21, on the face of the Consolidated Balance Sheet.  Refer to ASC 505 -10-50-4.

Notes to Consolidated Financial Statements

Note 7 – Preferred Units and Members’ Deficit, page F -21

18. Please explain to us why the liquidation preference requires the preferred units to be
presented outside of members’ deficit.  Refer to Rule 5 -02.27 of Re gulation S -X.

Common Units, page F -21

19. Please tell us the maximum number of common units that are authorized, and how this
differs from common units that are issued and outstanding.

Warrants for Common Units, page F -22

20. Please tell us why the warrants is sued with the Series C and D Convertible Notes are
recognized as liabilities.  Include the terms of these warrants and the authoritative
guidance as part of your response.

Note 8 – Commitments and Contingencies

Other Commitments, page F -24

21. We note your  discussion of the Carve -Out Plan on pages F -21 and F -24.  Please revise
the filing to disclose how any amounts payable under this plan will be recognized for
accounting purposes.

Item 15.  Recent Sales of Unregistered Securities, page II -2

22. Revise to provide the disclosure required by Regulation S -K Item 701.

Item 16.  Exhibits and Financial Statement Schedules, page II -3

23. Revise to disclose the exhibits you have filed and intend to file with the registration
statement.

Brett Moyer
Summit Semiconductor, LLC
November 27 , 2017
Page 5

You may contact Gary Newberry  at (202) 551 -3761  or Lynn Dicker, Senior Accountant,
at (202) 551 -3616  if you have questions regarding comments on the financial statements and
related matters.  Please contact  Caleb French  at (202) 551 -6947  or me at (202) 551 -3528  with
any o ther questions.

Sincerely,

 /s/ A manda Ravitz

 Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc:  David E. Danovitch, Esq.
 Robinson Brog Leinwand Greene Genovese and Gluck, P.C.