United States securities and exchange commission logo

                              February 24, 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.
Statement on Form S-1
                                                            Filed February 12,
                                                            File No. 333-253108

       Dear Mr. Cannon:

              We have reviewed your 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

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-1

       Cover Page

   1.                                                   We note your revised
disclosure regarding redemption of the subunits if you are unable to
                                                        consummate an initial
business combination "within 24 months." Please revise to clarify
                                                        whether you will redeem
such subunits if you are unable to consummate an initial
                                                        business combination
within 24 months from the closing of this offering.
       Financial Statements, page F-1

   2.                                                   We note your response
to prior comment 7 and believe your financial statements should
                                                        not be presented for a
period that crosses over your fiscal year end. Revise your financial
                                                        statement presentation
to include audited financial statements as of and for the period of
                                                        inception through
December 31, 2020. Refer to Rule 8-02 of Regulation S-X.
 Stephen N. Cannon
Archimedes Tech SPAC Partners Co.
February 24, 2021
Page 2

3.    Please obtain and file a revised legality opinion that opines on the
legality of each of the
      securities covered by the registration statement. For example, it is not
clear whether the
      shares of common stock included as part of the subunits or underlying the
public warrants
      are covered by the legality opinion, and the legality opinion does not
opine on the legality
      of the subunits and public warrants. We also note that the term "Shares"
is not defined,
      and it is not clear why the opinion opines on shares underlying "Public
        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

       You may contact Shannon Buskirk, Staff Accountant, at (202) 551-3717 or
Horowitz, Accounting Branch Chief, at (202) 551-3311 if you have questions
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.

FirstName LastNameStephen N. Cannon
                                                            Division of
Corporation Finance
Comapany NameArchimedes Tech SPAC Partners Co.
                                                            Office of Energy &
February 24, 2021 Page 2
cc:       Giovanni Caruso
FirstName LastName