United States securities and exchange commission logo
November 3, 2021
David Ly
Chief Executive Officer
Iveda Solutions, Inc.
460 S. Greenfield Road, Ste. 5
Mesa, Arizona 85206
Re: Iveda Solutions,
Inc.
Amendment No. 1 to
Registration Statement on Form 10-12G
Filed October 25,
2021
File No. 000-53285
Dear Mr. Ly:
We have reviewed your filing 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 these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response and any amendment you may file in
response to these
comments, we may have additional comments. Our references to prior
comments refer to
comments in our October 20, 2021 letter.
Amendment No. 1 to Form 10-12G filed October 25, 2021
Business, page 4
1. Disclosure added in
response to prior comment 1 notes that the liability protection of your
certification is
limited to the U.S. Please revise to further explain when products or
services you or MEGAsys
sells would be entitled to liability protection if your
certification is
renewed. For example, clarify whether MEGAsys, a Taiwan-based entity,
receives this liability
protection for any products or services it sells and whether a
condition to receiving
the liability protection is that the customer is U.S.-based.
Additionally, given
that the company depends on MEGAsys for the majority of its
revenue, expand your
disclosure to address how the lack of liability protection may impact
your results of
operations and clarify the benefit of the certification to the company as a
whole.
David Ly
FirstName LastNameDavid Ly
Iveda Solutions, Inc.
Comapany 3,
November NameIveda
2021 Solutions, Inc.
November
Page 2 3, 2021 Page 2
FirstName LastName
Risk Factors
Risks Related to Our Business
A Relatively Small Number of Key Customers..., page 9
2. Disclosure added in response to prior comment 2 indicates that Chungwa
Telecom
accounted for 25% of your revenue for the six months ended June 30,
2021. Please revise
here to disclose the percentage of revenue generated from this
customer for all periods
presented. Additionally, please file your agreement with Chungwa
Telecom. Refer to
Item 601(b)(10)(ii)(B) of Regulation S-K. Lastly, please also disclose
your total number
of customers for the six months ended June 30, 2020 and the years
ended December 31,
2019 and 2020.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
16
3. Disclosure added in response to prior comment 4 discusses the general
effects of COVID-
19 on your business. Please revise to also quantify any material
impacts that COVID-19
had on your business, including your results of operations and
revenue, for the year ended
December 31, 2020 and the first quarter of 2021.
Liquidity and Capital Resources, page 21
4. Please revise here to discuss the concentration of revenue and
accounts receivable as of
and for the six-month period ending June 30, 2021 based on
consolidated amounts. In this
regard, your current discussion of the percentage of significant
customers' accounts
receivable is based only on your Taiwan-based segment and your
discussion of the
percentage of revenue from three significant customers is calculated
from revenue for the
quarter ending June 30, 2021.
5. Please revise to clarify the portion of the $260,000 short-term debt
due between August
2021 to February 2022 that is past its maturity date or has been
repaid as of the date of
your filing, if any. In addition, include a discussion of the $422,688
loan from Shanghai
Bank due September 2021. In this regard, your liquidity disclosure
only discusses the
outstanding debt related to Iveda US. Lastly, provide us with a
rollforward of your short-
term debt from December 31, 2020 to June 30, 2021 and ensure that the
issuance of any
new debt and the repayment or conversion of debt outstanding during
the six months
ended June 30, 2021 agrees to your financial statements and related
footnote disclosures.
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.
David Ly
Iveda Solutions, Inc.
November 3, 2021
Page 3
You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Alexandra
Barone, Staff
Attorney, at (202) 551-8816 or Mitchell Austin, Staff Attorney, at (202)
551-3574 with any other
questions.
Sincerely,
FirstName LastNameDavid Ly
Division of
Corporation Finance
Comapany NameIveda Solutions, Inc.
Office of Technology
November 3, 2021 Page 3
cc: Peter Campitello
FirstName LastName