October 31, 2017
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attn: | Amanda Ravitz |
| Laurie Abbott |
| Re: | ACM Research, Inc. |
Registration Statement on FormS-1
FileNo. 333-220451
Acceleration Request
Requested Date: Thursday, November 2, 2017
Requested Time: 5:00 p.m., Eastern Daylight Time
Ladies and gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), Roth Capital Partners, LLC hereby joins ACM Research, Inc. in requesting that the Securities and Exchange Commission (the “Commission”) take appropriate action to cause the Registration Statement on FormS-1 (FileNo. 333-220451) to become effective on November 2, 2017, at 5:00 p.m., Eastern Daylight Time, or as soon as practicable thereafter.
Additionally, pursuant to Rule 460 of the Act, we hereby advise you that approximately 447 copies of the Preliminary Prospectus, dated October 25, 2017, were distributed by us from October 25, 2017 through the date hereof to underwriters, institutions, dealers and others.
We will comply, and have been informed by the participating underwriters that they will comply, with the requirements of Rule15c2-8 under the Securities Exchange Act of 1934, as amended, to the extent applicable.
Very truly yours,
Roth Capital Partners, LLC | ||
| By: | /s/ Aaron M. Gurewitz | |
Name: Aaron M. Gurewitz Title: Head of Equity Capital Markets | ||
| cc: | Michael Maline, Goodwin Procter LLP |
Mark L. Johnson, K&L Gates LLP
