February 5, 2018

Amanda Ravitz

Assistant Director

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

Draft Registration Statement on Form S-1

Submitted October 31, 2017

CIK No. 0001682149

Dear Ms. Ravitz:

This letter responds to the Staff’s comment letter dated November 27, 2017 relating to the above-captioned registration statement. For your convenience, we have restated the Staff’s comments and have provided the Company’s response below such comments.

General

We converted to a corporation, effective December 31, 2017, and as such, revised the disclosures throughout the registration statement accordingly.

As of the date of this response, we have not utilized any written communications nor has it yet authorized any other person to do so on its behalf to present to potential investors in reliance on Section 5(d).

Prospectus Cover Page

We have revised applicable disclosure on the cover page accordingly.

The cover page has been revised accordingly to clarify that the underwriting is being conducted on a “best efforts.”

We have revised the disclosure throughout the draft registration statement accordingly to reflect the anticipatory nature of the disclosure.

Overview, page 1

We have advised the printer not to hyperlink any URL addresses and further, for each URL address we added disclosure that the information contained in or accessible through such website is not part of the prospectus or the registration statement of which the prospectus forms a part, and is intended for informational purposes only, consistent with afore-referenced obligations pursuant to Release 33-7856.

The customers highlighted in our overview and throughout our registration statement were done so because: (a) they represent our most significant customers in terms of engineering coordination, significant projects, and existing order and revenue; and (b) they represent the most aggressive segment of our industry in driving the use of wireless audio. The fact that they represent well-known brand names is purely coincidental.

Our Technology, page 2

A prototype version of our software technology has been demonstrated to select customers (pursuant to confidentiality agreements) at the recent 2018 Consumer Electronics Show in Las Vegas, NV. We plan to use approximately $3M from the IPO to productize our intellectual property through continued invention and robust testing.

We have revised the disclosure accordingly.

WiSA Association, page 2

For products with a WiSA Certification, WiSA also creates, maintains and manages testing criteria and specifications for all products to be listed, marketed and sold. WiSA Certification is an industrywide “stamp of approval” certifying that a product is interoperable with other WiSA Certified products and has passed several high-performance tests ensuring low levels of latency, tight channel synchronization. As owners of WiSA, LLC, Summit certifies all WiSA products. Summit does not actually sell any WiSA-certified products; however, it does distribute the technology to enable products to meet the WiSA certification test specifications. Currently, WiSA Certified products are required to use Summit modules in order to meet the standards set by the association. As a result, WiSA members purchase modules from us in order to build their products.

We have revised the disclosure accordingly.

Dilution, page 27

We have added disclosure that assuming an initial public offering price of $XX per share (the midpoint of the range), warrants could be exercised which would result in the increase to the pro forma as adjusted net tangible book value by approximately $XX per share. We have also added disclosure with respect to the amount of warrants that are outstanding.

Liquidity and Capital Resources, page 32

We revised the disclosure to state that assuming we raise at least a net of $7 million in the IPO, we will use the proceeds to pay for the amounts described in that paragraph. As such, we do not plan on raising additional capital to finance those items. In the event that we fail to raise such amount, we will need to raise additional capital.

What Makes Summit Unique, page 36

We have added the additional information accordingly.

Certain Relationships and Related Person Transactions, page 49

Jonathan Gazdak is a related party since he is the managing director of Alexander Capital, L.P.

(who is an underwriter for the IPO) and is on our board of directors. We have added disclosure that Alexander Capital, L.P. is acting as an underwriter for the IPO, and as such, is receiving underwriter discounts and commissions.

Preferred Membership Interest Units, page 55

Given the conversion from a limited liability company to a stock corporation and the addition of blank check preferred, we have revised the disclosure to reflect the new capital structure. We have also added disclosure that any current outstanding preferred stock will be converted to common stock upon completion of the IPO and any future issuances of preferred stock will dilute the investors in the IPO.

Choice of Forum, page 56

We have revised the disclosure accordingly and added an appropriate risk factor.

Material U.S. Federal Income Tax Considerations, page 58

We respectfully believe that Form S-1 does not require the inclusion of a section addressing the tax consequences of acquiring, owning or disposing of an issuer’s securities. Notwithstanding this, the Company determined to include a general summary of the material United States federal income tax consequences in the Registration Statement in order to provide additional information to investors. However, such section of the Registration Statement does not include any representations as to the tax consequences to investors in the offering; rather, it provides general disclosure related to the tax treatment of acquiring, holding and disposing of the Company’s securities. Item 601(b)(8) of Regulation S-K requires that a tax opinion be filed as an exhibit to a registration statement only if a representation as to tax consequences is set forth in the registration statement. The tax section included in the Registration Statement does not provide any representations as to tax consequences. Accordingly, we respectfully believe that no tax opinion is required.

Consolidated Financial Statements

Consolidated Balance Sheets, page F-2

We have disclosed the liquidation preference of the preferred stock on the face of the Consolidated Balance Sheet on page F-3.

Notes to Consolidated Financial Statements

Note 7 – Preferred Units and Members’ Deficit, page F-21

The preferred units are presented outside of the members’ deficit because in the event of a change in control of the Company, the holders of the preferred units would be entitled to receive a distribution of the legally available assets of the Company. In accordance with Rule 5-02.27(a)(3) of Regulation S-X, a change in control of a company is considered an event that is not solely within the control of such company.

Common Units, page F-21

Subsequent to the conversion from a limited liability company to a corporation, the Company now has 200,000,000 shares of common stock authorized, and 20,000,000 shares of blank check preferred stock authorized. Prior to the conversion, there were 5,122,221 units authorized and outstanding, as disclosed on the face of the consolidated balance sheet on page F-3.

Warrants for Common Units, page F-22

The warrants issued with the Series C and Series D Convertible Notes are recognized as liabilities as they contain price protection rights which qualify as a variable number of shares at settlement in accordance with ASC 480-10-25-14. If the Company issues units at a price per share less than the exercise price then in effect or without consideration, then the exercise price of the warrants will be adjusted as specified in the warrant agreement. We have revised the disclosures on page F-24 to include such information.

Note 8 – Commitments and Contingencies

Other Commitments, page F-24

We have revised the disclosure on page F-26 to disclose that any amounts payable under this plan will be recognized as compensation in the consolidated statement of operations during the period the Company becomes obligated to make such payments.

Item 15. Recent Sales of Unregistered Securities, page II-2

We have added the required disclosure.

Item 16. Exhibits and Financial Statement Schedules, page II-3

We revised the exhibit table accordingly.

If you have any questions regarding our responses, please contact David E. Danovitch at 212-603-6300 or ded@robinsonbrog.com.