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