United States securities and exchange commission logo
January 25, 2023
Mark McKechnie
Chief Financial Officer, Executive Vice President and Treasurer
ACM Research, Inc.
42307 Osgood Road, Suite I
Fremont, California 94539
Re: ACM Research, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Form 10-Q for
Fiscal Quarters Ended June 30, 2022
File No. 001-38273
Dear Mark McKechnie:
We have reviewed your December 5, 2022 response to our comment
letter and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this comment, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
October 26, 2022 letter.
Form 10-Q for the Fiscal Quarters Ended September 30, 2022
Item 2. Managements Discussion and Analysis of Financial Condition and
Results of Operations,
page 39
1. You state on page 14 of
your Form 10-Q that in October, 2022 the U.S. Department of
Commerce enacted new
rules aimed at restricting U.S. support for the PRC s ability to
manufacture advanced
semiconductors." Please describe the material effects on your
business of such new
rules and provide related risk factor disclosure.
You may contact Inessa Kessman, Senior Staff Accountant, at
202-551-3371 or Robert
Littlepage, Accounting Branch Chief, at 202-551-3361 if you have any
questions.
Mark McKechnie
ACM Research, Inc.
January 25, 2023
Page 2
FirstName LastNameMark McKechnie Sincerely,
Comapany NameACM Research, Inc.
Division of Corporation Finance
January 25, 2023 Page 2 Office of Technology
FirstName LastName