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                              December 18, 2023

       David Hsu
       Chief Executive Officer
       SolarMax Technology, Inc.
       3080 12th Street
       Riverside, CA 92507

                                                        Re: SolarMax
Technology, Inc.
                                                            Amendment No. 10 to
Registration Statement on Form S-1
                                                            Filed December 4,
2023
                                                            File No. 333-266206

       Dear David Hsu:

                                                        We have reviewed your
amended registration statement and have the following comment.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a 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 letter, we may have additional comments.

       Amendment No. 10 to Registration Statement on Form S-1 filed December 4,
2023

       Notes to Consolidated Financial Statements for the Nine Months Ended
September 30, 2023 and
       2022 (Unaudited)
       2. Basis of Presentation and Summary of Significant Accounting Policies
       Warranties, page F-17

   1.                                                   We note your disclosure
that in 2016, as a result of the bankruptcy of a Chinese panel
                                                        supplier from whom the
Company purchased solar modules, the Company reclassified the
                                                        liability related to
unpaid retentions to warranty liability in the amount of $651,000 and
                                                        that given that the
Company has not received any claims against the liability since that
                                                        time, the Company
reversed the liability against cost of revenue during the third quarter of
                                                        2023. Please tell us
how the Company considered the guidance in ASC 405-20-40-1b in
                                                        determining that it
should derecognize the liability. Specifically, your response should
                                                        indicate any analysis
the Company conducted to determine that it was legally released
                                                        under such liability.
 David Hsu
SolarMax Technology, Inc.
December 18, 2023
Page 2

       Please contact Ameen Hamady at 202-551-3891 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ronald (Ron) E. Alper at 202-551-3329 or Pam Long at 202-551-3765 with
any other
questions.



                                                           Sincerely,
FirstName LastNameDavid Hsu
                                                           Division of
Corporation Finance
Comapany NameSolarMax Technology, Inc.
                                                           Office of Real
Estate & Construction
December 18, 2023 Page 2
cc:       Asher Levitsky
FirstName LastName