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                              August 29, 2022

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

                                                        Re: SolarMax
Technology, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed August 12,
2022
                                                            File No. 333-266206

       Dear Mr. Hsu:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
August 3, 2022 letter.

       Amendment No. 1 to Registration Statement on Form S-1 filed August 12,
2022

       Prospectus Summary
       Permission required to obtain from Chinese authorities to operate and
issuer securities to foreign
       investors, page 9

   1.                                                   We reissue comment 1.
Please disclose in this section 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. This
                                                        includes the statement
that "neither we nor our PRC subsidiaries are currently subject to
                                                        any pre-approval
requirement from the CAC to operate our business or conduct this
                                                        offering, subject to
PRC government   s interpretation and implementation of the draft
                                                        measures after they
take effect." Please reconcile with the disclosure that "because of our
 David Hsu
FirstName LastNameDavid
SolarMax Technology,  Inc. Hsu
Comapany
August 29, NameSolarMax
           2022            Technology, Inc.
August
Page 2 29, 2022 Page 2
FirstName LastName
         China Segment, we could be subject to additional requirements that we
obtain pre-
         approval of the CSRC and potentially other regulatory authorities to
pursue this offering,
         including a cybersecurity review potentially required under the
Cybersecurity Review
         Measures." Please clarify the preapproval that you may be subject to
and discuss whether
         you have obtained such preapproval. To the extent you have not, please
provide clear
         disclosure of the risks and potential impact failure to obtain such
preapprovals may have
         upon the company and this offering.
Risk Factors, page 16

2.       We partially reissue comment 2. Please expand upon your risk factor on
page 38
         discussing inflation and supply chain issues to clearly discuss the
extent to which your US
         operations have been affected by supply chain issues to date.
Similarly revise the
         disclosure in the MD&A.
Use of Proceeds, page 63

3.       We reissue comment 4. Please revise this section to clearly disclose
that the proceeds
         may be used for the payment of short term debt and include the amount
of proceeds
         allocated to such payments. In addition, for each debt, please
disclose the interest rate and
         maturity date.
Capitalization, page 64

4.       It does not appear that you have updated the as adjusted column to
reflect the expected
         repayment of the $2.0 million note to an unrelated person that you
refer to within footnote
         1 to the table. Please revise or advise.
Management's Discussion and Analysis, page 65

5.       We note your response to comment 7 and we reissue it in part. Please
specify whether the
         principal factors contributing to the inflationary pressures and
supply chain issues the
         company has experienced are known trends, events, and uncertainties
that have materially
         impacted your results of operations or capital resources. Identify
actions taken or planned,
         if any, to mitigate the impact of these factors. Finally, please
discuss whether these
         factors materially affect your outlook or business goals.
Notes to Consolidated Financial Statements
2. Basis of Presentation and Summary of Significant Accounting Policies
Contract Balances, page F-58

6.       We note your response to our comment 10. Please address the following:
             Please tell us when such perfunctory administrative procedures are
expected to be
            accomplished and as a result such amounts will be billed as we note
that the most
            recent China project has been complete since June 30, 2021. In
addition, please tell us
            the factors that led the Company to believe such unbilled amounts
are still considered
 David Hsu
SolarMax Technology, Inc.
August 29, 2022
Page 3
           realizable as of March 31, 2022. To the extent the Company has began
billing such
           amounts subsequent to March 31, 2022, please tell us how much of the
outstanding
           unbilled amounts have been billed and how much have been
subsequently collected
           through the latest date available.
             Further, to the extent the Company is aware of any negative trends
that may be
           impacting its ability to bill and collect its unbilled receivables,
please revise your
           filing to disclose such trends in your MD&A. We remind you that your
disclosures in
           your MD&A should provide quantified material trends and known
material
           uncertainties when available so that investors can understand the
business through the
           eyes of management. See Item 303 of Regulation S-K. See also Section
501 of the
           Financial Reporting Codification.
Exhibits

7.    We reissue comment 11. Please revise the opinion of counsel filed as
Exhibit 5.2 to
      consent to each section where counsel is named in the prospectus.
        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,
FirstName LastNameDavid Hsu
                                                           Division of
Corporation Finance
Comapany NameSolarMax Technology, Inc.
                                                           Office of Real
Estate & Construction
August 29, 2022 Page 3
cc:       Asher Levitsky
FirstName LastName