United States securities and exchange commission logo
May 6, 2021
Chenlong Tan
Chief Executive Officer
iPower Inc.
2399 Bateman Avenue
Duarte, CA 91010
Re: iPower Inc.
Amendment No. 3 to
Registration Statement on Form S-1
Filed May 5, 2021
File No. 333-252629
Dear Mr. Tan:
We have reviewed your amended registration statement 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 letter by amending your registration
statement and providing the
requested information. If you do not believe our comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell
us why in your
response.
After reviewing any amendment to your registration statement and
the information you
provide in response to this comment, we may have additional comments.
Amendment No. 3 to Registration Statement on Form S-1 Filed May 5, 2021
General
1. We note that you have
deleted language (i) that you cater primarily to home cultivators
growing specialty
crops, including cannabis and hemp, (ii) that you intend to leverage
the growth of cannabis
and CBD products, in tandem with its increased legalization, to
further build [y]our
brand and promote [y]our hydroponics equipment and products within
the cannabis community,
and (iii) that you believe that your entry into cannabis
friendly markets
like Europe will accelerate your growth and further diversify your
customer base.
In an appropriate
place, to the extent you have previously targeted customers in the
cannabis industry as
part of your historical revenue generation and planned growth
Chenlong Tan
iPower Inc.
May 6, 2021
Page 2
strategy and that target market has shifted, as suggested by the deleted
disclosure, please
discuss how that shift may impact your business and financial position.
Otherwise, please
tell us why you have deleted such disclosure.
Please contact Taylor Beech at 202-551-4515 or Mara Ransom at
202-551-3264 with
any questions.
Sincerely,
FirstName LastNameChenlong Tan
Division of
Corporation Finance
Comapany NameiPower Inc.
Office of Trade &
Services
May 6, 2021 Page 2
cc: Megan Penick
FirstName LastName