United States securities and exchange commission logo





                               June 9, 2020

       Zeynep Hakimoglu
       President and Chief Executive Officer
       ClearOne, Inc.
       5225 Wiley Post Way, Suite 500
       Salt Lake City, UT 84116

                                                        Re: ClearOne, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed May 7, 2020
                                                            File No. 333-238085

       Dear Ms. Hakimoglu:

              We have limited our review of your registration statement to the
issue that we have
       addressed in our comment. In our comment we may ask you to provide us
information so that
       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 that our comment applies to
your facts and
       circumstances or do not believe that an amendment is appropriate, please
tell us why in your
       response.

              After reviewing any amendment to your registration statement and
the information that
       you provide in response to these comments, we may have additional
comments.

       Pre-effective Amendment 1 to Registration Statement on Form S-3 filed
June 1, 2020

       Our certification of incorporation designates the Court of Chancery,
page 4

   1.                                                   Please revise the
disclosures in the first paragraph on page 5 to reflect the scope of Article
                                                        X of your certificate
of incorporation.
               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 before the requested effective date
of the registration
       statement.
 Zeynep Hakimoglu
ClearOne, Inc.
June 9, 2020
Page 2

        Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 or
Asia Timmons-
Pierce, Special Counsel, at (202) 551-3754 with any questions.



                                                         Sincerely,
FirstName LastNameZeynep Hakimoglu
                                                         Division of
Corporation Finance
Comapany NameClearOne, Inc.
                                                         Office of
Manufacturing
June 9, 2020 Page 2
cc:       Michael T. Dunn, Esq.
FirstName LastName