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                               June 9, 2022

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

                                                        Re: SolarMax
Technology, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted May 16,
2022
                                                            CIK No. 0001519472

       Dear Mr. Hsu:

              We have reviewed your draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form S-1 Submitted May 16, 2022

       General

   1.                                                   Please create a
separate Enforceability of Civil Liabilities section for the discussion of the
                                                        enforcement risks
related to civil liabilities due to some of your officers and directors
                                                        being located outside
the United States, including China. Please disclose that it will be
                                                        more difficult to
enforce liabilities and enforce judgments on those individuals. For
                                                        example, revise to
discuss more specifically the limitations on investors being able to
                                                        effect service of
process and enforce civil liabilities in china, and cost and time
                                                        constraints. Also,
please revise your risk factor on page 49, consistent with the separate
                                                        section.
 David Hsu
FirstName  LastNameDavid
SolarMax Technology, Inc. Hsu
Comapany
June 9, 2022NameSolarMax Technology, Inc.
June 9,
Page 2 2022 Page 2
FirstName LastName
2.       Please update the disclosure throughout the prospectus as of the most
recent practicable
         date. For instance, we note the disclosure on pages 31 and 97 that
your contractor license
         expires on December 31, 2021, the disclosure on page 52 that your
qualification certificate
         expires March 4, 2021, and the disclosure on page 96 regarding
liquidated damages if you
         don't complete a public offering by May 12, 2017. Please also update
generally to reflect
         the changes since the prior registration statement was filed. For
instance, we note the
         disclosure on page 57 that Ching Liu is your executive vice president,
chief strategy
         officer and treasurer; however, the management section no longer
reflects her as an
         executive officer. Similarly, we note the disclosure on page 74 that
"We expect that the
         China segment will continue to generate both higher revenue and a
lower gross margin
         than the United States segment in the future, resulting in the China
segment continuing to
         have a negative impact on our consolidated gross margin." However, we
note the first
         risk factor on page 16 regarding the inability to develop new business
in China and the
         disclosure on page 94 that regarding the China segment you do not have
any agreements
         or understandings and cannot give any assurance that you will be able
to develop any
         significant revenue, if any, from this type of project.
Permission required to obtain from Chinese authorities to operate and issuer
securities to foreign
investors, page 9

3.       Please disclose how you determined that you are not required to obtain
any permissions
         or approvals from Chinese authorities to operate your business and to
offer the securities
         being registered to foreign investors. To the extent you are relying
upon the opinion of
         counsel, please identify counsel in the disclosure and file their
consent as an exhibit.
         Please also reconcile the disclosure in this section regarding the
lack of permissions and
         approvals from Chinese authorities to operate your business with
disclosure elsewhere,
         including the risk factors section, regarding licenses required to
operate in China.
Use of Proceeds, page 62

4.       We note that the proceeds may be used for working capital and other
corporate purposes,
         including payment of short term debt. Please clarify the amount
allocated to the
         repayment of debt and to the extent the proceeds may not be sufficient
to repay all the
         debt, please clearly disclose the amount allocated to each debt, for
instance the partnership
         loans. For each debt to be discharged, please set forth the interest
rate and maturity of
         such indebtedness. See Instruction 4 to Item 504 of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
66

5.       We note your disclosure that as a result of the termination of the
merger agreement with
         Alberton, you do not anticipate that you will be able to collect any
of the loans that were
         granted to Alberton and Alberton's sponsor, and that you anticipate
recognizing an
         impairment in the full amount of these loans in the first quarter of
2022. We further note
         your disclosure on page F-64 that because the merger has been
terminated, you will
 David Hsu
SolarMax Technology, Inc.
June 9, 2022
Page 3
         provide for a reserve for the loans to Alberton's sponsor and to
Alberton for approximately
         $2.3 million and will expense approximately $1.0 million in
capitalized costs related to
         the merger in the second quarter of 2022. Please clarify the
inconsistency between both
         disclosures.
Liquidity and Capital Resources, page 78

6.       We note your disclosure on page 84 that you believe that the
anticipated cash available at
         the effective time of the offering, together with cash generated by
your operations and
         available credit facilities should enable you to meet your cash
requirements for at least the
         twelve months from the effective time of the offering. Please address
the following:
             We note your history of negative cash flows from operating
activities. Please tell us
              and revise your filing to clarify, if applicable, that you may
continue to have negative
              cash flows from operating activities for the twelve months from
the effective time of
              the offering.
             With regards to your disclosure of available credit facilities, we
are unable to locate
              your disclosure of such facilities in your filing. Please revise
or advise.
             To the extent you are primarily relying on the proceeds from this
offering to meet
              your liquidity needs, please clearly disclose this fact or
advise.
Business, page 93

7.       Please revise the disclosure on page 97 to clarify the contingent
liability relating to the
         debt settlement agreement.
Management, page 126

8.       For each director, briefly discuss the specific experience,
qualifications, attributes or skills
         that led to the conclusion that the person should serve as a director
for the registrant at the
         time that the disclosure is made, in light of the registrant's
business and structure. See
         Item 401(e)(1) of Regulation S-K.
Summary Compensation Table, page 128

9.       We note the disclosure on page 129 that you have a 2017 employment
agreement with Mr.
         Brown that provides for an annual salary of $350,000. We note the
summary
         compensation table for 2020 reflects a salary of $308,437. Please
reconcile or advise.
Director
FirstNameCompensation,
           LastNameDavid pageHsu
                               131
Comapany
10.        NameSolarMax
       Please                Technology,
              include all of your         Inc.
                                  non-management directors in the directors'
compensation table.
June 9,See
       2022Item 401(r)(2)(i)
             Page  3          of Regulation S-K.
FirstName LastName
 David Hsu
FirstName  LastNameDavid
SolarMax Technology, Inc. Hsu
Comapany
June 9, 2022NameSolarMax Technology, Inc.
June 9,
Page 4 2022 Page 4
FirstName LastName
Articles of Incorporation and Bylaw Provisions, page 137

11.      We note the disclosure on page 137 that "Our bylaws also provide that
any person who
         acquires equity in us shall be deemed to have notice and consented to
the forum selection
         provision of our bylaws, which require actions to be brought only in
state count in Clark
         County, Nevada." Please reconcile with the bylaws filed as Exhibit
3.2, which
         designate a state or federal court located in the City and County of
Riverside, California
         as the exclusive forum. We also note the disclosure indicates that the
forum selection
         provision in the company   s bylaws does not apply to claims brought
under the Securities
         Act or the Securities Exchange Act. Please revise the bylaws
consistent with the
         disclosure or advise.
        You may 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 Howell at
202-551-3357
with any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Real
Estate & Construction
cc:      Asher Levitsky