United States securities and exchange commission logo





                              October 20, 2021

       David Ly
       Chief Executive Officer
       Iveda Solutions, Inc.
       460 S. Greenfield Road, Ste. 5
       Mesa, Arizona 85206

                                                        Re: Iveda Solutions,
Inc.
                                                            Registration
Statement on Form 10-12G
                                                            Filed September 23,
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.

       Form 10-12G filed September 23, 2021

       Business, page 4

   1.                                                   You disclose here and
elsewhere that you received a SAFETY Act designation from the
                                                        Department of Homeland
Security in 2009, which was renewed in 2019, and a
                                                        certification in 2016,
which you are currently in the process of renewing. Please revise to:

                                                              Clearly describe
the interaction and differences between the designation and the
                                                            certification. In
this regard, disclosure on page 11 indicates the designation was
                                                            "elevated" to a
certification, while other disclosures - such as your disclosure that you
                                                            renewed the
designation in 2019 - suggest that you hold both the designation and
                                                            certification
concurrently;

                                                              Clarify when your
2016 certification expires and whether your video surveillance
 David Ly
Iveda Solutions, Inc.
October 20, 2021
Page 2
              products and services are considered to be certified during the
certification renewal
              process;

                Describe the certification renewal process, including the steps
remaining to complete
              the process, and how you will communicate the results of this
process to investors;
              and

                Clarify the significance of the designation and certification
to MEGAsys, your
              Taiwan-based subsidiary, which has recently accounted for a
significant portion of
              your total revenues.
Risk Factors
Risks Related to Our Business
A relatively small number of key customers..., page 9

2.       You state here that revenue from three of your Taiwan-based customers
accounted for
         46% of your Taiwan-based segment revenue for the quarter ended June
30, 2021. Please
         revise to identify these customers and disclose the material terms of
your agreements with
         them, including the term of the agreements and termination provisions.
To provide
         context for this disclosure, also revise to disclose the total number
of customers for each
         period presented. Refer to Item 101(h)(4)(vi) of Regulation S-K.
We rely on MEGAsys, our Taiwan subsidiary, for a significant portion of our
revenue, page 10

3.       Please revise to also disclose the percentage of your revenue
accounted for by MEGAsys,
         your Taiwan-based subsidiary, for the period ended June 30, 2021.
Please also revise
         your business and MD&A sections to highlight your dependence on
MEGAsys.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
16

4.       Please update your disclosure in this section and in your risk factors
to discuss the impact
         that COVID-19 has had on your business, including on your results of
operations and
         revenue. Refer to CF Disclosure Guidance: Topic Nos. 9 and 9A for
additional guidance.
Results of Operations
Net Revenue,
FirstName    page 19
           LastNameDavid Ly
Comapany
5.    The NameIveda
            first sentenceSolutions, Inc. compares the three months ended June
30, 2021 to the
                           in this section
Octoberthree months
         20, 2021     ended
                    Page 2 June 30, 2015. Please revise to correct this
apparent error.
FirstName LastName
 David Ly
FirstName  LastNameDavid  Ly
Iveda Solutions, Inc.
Comapany
October 20,NameIveda
            2021      Solutions, Inc.
October
Page 3 20, 2021 Page 3
FirstName LastName
Executive Compensation, page 26

6.       Please revise this section as appropriate to include (i) a narrative
description of any
         employment arrangements, (ii) a table disclosing outstanding equity
awards as well as a
         narrative description of any equity incentive plans, and (iii) any
director compensation.
         Refer to Item 402 of Regulation S-K.
Market Price and Dividends on the Registrant's Common Equity and Related
Stockholder
Matters, page 28

7.       You disclose here that your common stock is currently quoted on the
OTC Markets.
         Please revise to clarify on which OTC Markets tier your common stock
is quoted. Also,
         ensure you include the information required by Item 201(a)(1)(ii) of
Regulation S-K.
Description of Securities, page 29

8.       Please expand your disclosure to discuss all significant rights and
features associated with
         your common stock. In this regard, based on your disclosure on page
48, it appears that
         your common stock has certain dividend and liquidation features that
should be
         highlighted in this section. See Item 202 of Regulation S-K.
Consolidated Financial Statements
Note 1. Summary of Significant Accounting Policies
Revenue and Expense Recognition, page 39

9.       Please revise to provide your revenue recognition policy for each type
of revenue
         described, including monthly licensing fees, hardware sales, project
revenues, etc.
         Describe the nature of each revenue type and the timing of revenue
recognition. Also,
         ensure that your policy disclosures and revenue recognition comply
with the current
         revenue guidance in ASC 606 and include the applicable adoption
disclosures pursuant to
         ASC 606-10-65-1.
Concentration, page 40

10.      We note from your liquidity discussion that revenue from three
customers comprised
         approximately 45% of total revenue and accounts receivable from two
customer
         comprised 54% of total segment accounts receivable. Please revise to
include a
         discussion of concentration of credit risk associated with these
customer pursuant to ASC
         275-10-50-18. Also, separately disclose the total revenue from each
customer that
         provided more than 10% of your revenue for each period presented.
Refer to ASC 280-
         10-50-42.
Note 3. Short-Term Debt, page 46

11.      Please revise here to disclose the maturity date for each of the loans
and debentures
         outstanding as of each period end. Also, revise MD&A to include a
discussion regarding
 David Ly
Iveda Solutions, Inc.
October 20, 2021
Page 4
       the impact of all outstanding debt on your liquidity and capital
resources and address how
       you intend to repay such debt, particularly amounts that are currently
past their maturity.
       Refer to Item 303(a) of Regulation S-K
Consolidated Financial Statements at and for the Six Months Ended June 30,
2021, page 53

12.    Please revise to label your interim financial statements as "unaudited"
where appropriate.
        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.

        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
October 20, 2021 Page 4
cc:       Peter Campitello
FirstName LastName