United States securities and exchange commission logo
March 5, 2021
Stephen N. Cannon
Chief Executive Officer
Archimedes Tech SPAC Partners Co.
2093 Philadelphia Pike #1968
Claymont, DE 19703
Re: Archimedes Tech
SPAC Partners Co.
Amendment No. 1 to
Registration Statement on Form S-1
Filed March 1, 2021
File No. 333-253108
Dear Mr. Cannon:
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.
Amendment No.1 to Registration Statement on Form S-1
Financial Statements, page F-1
1. Revise your
presentation to include only financial statements as of and for the period
ending December 31,
2020. Expand your subsequent events footnote as necessary to
disclose events or
transactions occurring after December 31, 2020.
Stephen N. Cannon
FirstName
ArchimedesLastNameStephen N. Cannon
Tech SPAC Partners Co.
Comapany
March NameArchimedes Tech SPAC Partners Co.
5, 2021
March2 5, 2021 Page 2
Page
FirstName LastName
You may contact Shannon Buskirk, Staff Accountant, at (202) 551-3717 or
Ethan
Horowitz, Accounting Branch Chief, at (202) 551-3311 if you have questions
regarding
comments on the financial statements and related matters. Please contact Karina
Dorin, Staff
Attorney, at (202) 551-3763 or Laura Nicholson, Special Counsel, at (202)
551-3584 with any
other questions.
Sincerely,
Division of
Corporation Finance
Office of Energy &
Transportation
cc: Giovanni Caruso