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                            February 5, 2021

       Gordon Roth
       Chief Financial Officer
       Roth CH Acquisition III Co.
       888 San Clemente Drive, Suite 400
       Newport Beach, CA 92660

                                                        Re: Roth CH Acquisition
III Co.
                                                            Registration
Statement on Form S-1
                                                            Filed January 12,
2021
                                                            File No. 333-252044

       Dear Mr. Roth:

              We have reviewed your 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.

       Registration Statement on Form S-1 Filed January 12, 2021

       Use of Proceeds, page 38

   1.                                                   Please revise this
section to address the business combination marketing agreement and
                                                        the amount of the
payments pursuant to the marketing agreement with Roth and Craig-
                                                        Hallum in a footnote or
other text.
               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.

              Refer to Rules 460 and 461 regarding requests for acceleration.
Please allow adequate
       time for us to review any amendment prior to the requested effective
date of the registration
       statement.
 Gordon Roth
Roth CH Acquisition III Co.
February 5, 2021
Page 2

       You may contact Eric McPhee at 202-551-3693 or Wilson Lee at
202-551-3468 if you
have questions regarding the financial statements and related matters. Please
contact Ronald
(Ron) E. Alper at 202-551-3329 or David Link at 202-551-3356 with any other
questions.



                                                          Sincerely,
FirstName LastNameGordon Roth
                                                          Division of
Corporation Finance
Comapany NameRoth CH Acquisition III Co.
                                                          Office of Real Estate
& Construction
February 5, 2021 Page 2
cc:       Giovanni Caruso
FirstName LastName