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