John McIlvery
	Partner
	Voice/Fax	818.444.4502
	Mobile	626.704.0758
	E-Mail	jmcilvery@stubbsalderton.com

September 3, 2020

VIA EDGAR

Securities and Exchange Commission
Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549
Attn: Matthew Derby, Staff Attorney

Ladies and Gentlemen:

On behalf of Interlink Electronics Inc. (the “Company”), we have enclosed for filing the Company’s Amendment No. 1 (the “Amendment No. 1”) to Registration Statement on Form 10 (the “Registration Statement”).

In addition to filing Amendment No. 1, we hereby provide the following responses in reply to the comment letter dated August 27, 2020 (the “Comment Letter”) transmitted to the Company by the staff of the United States Securities and Exchange Commission, Division of Corporation Finance (the “Staff”). The factual information provided herein relating to the Company has been made available to us by the Company. Paragraph numbering used for each response set forth below corresponds to the numbering used in the Comment Letter.

Registration Statement on Form 10

Special Note Regarding Forward Looking Statements, page 3

The Company has deleted all references in Amendment No. 1 to the safe harbor for forward-looking statements provided by the Private Securities Litigation Reform Act in response to the Staff’s comment.

Securities and Exchange Commission Division of Corporation Finance September 3, 2020 Page 2

Business, page 5

The Company’s business is not dependent on customer contracts, including contracts with any of those customers that represented at least 10% of the Company’s revenue for 2019. As a supplier of parts, from time to time the Company is party to vendor contracts with certain of its customers that provide general terms and conditions of sale. These contracts, however, do not impose material binding obligations on the Company or provide the Company with any material rights or benefits. Rather, these contracts govern the terms and conditions of sale, if and to the extent sales occur pursuant to separate purchase orders from the customer. For these reasons, the Company has omitted disclosure of the material terms of any agreements with its customers, including the identity of its top three customers. The Company has provided additional disclosure about the nature of its contractual relationships with customers under the heading “Business – Our Customers”, on page 10 of Amendment No. 1.

The Company also has included additional risk factor disclosure regarding customer concentration in response to the Staff’s comment. The revised risk factor disclosure appears on page 13 of Amendment No. 1.

The Company was founded in 1985 to commercialize its patented Force-Sensing Resistor (“FSR®”) technology, a novel invention that paved the way for industry-wide adoption of force sensing technologies. Since its invention of FSR, the Company has produced 100’s of millions of these printed sensors. The Company has continued to lead its industry with many technological advances using the Company’s printed electronics expertise, including the following notable achievements that substantiate its leadership position:

Securities and Exchange Commission Division of Corporation Finance September 3, 2020 Page 3

The Company believes that its many technological advancements in printed electronics over the past 30 plus years support its statement that the Company is a leader in the printed electronics industry.

Our Customers, page 9

The Company has revised the disclosure under the heading “Business – Our Customers”, on page 10 of Amendment No. 1 to disclose those countries that contributed more than 10% of revenues in 2019.

Manufacturing Operations and Principal Suppliers, page 10

The Company does purchase some of the materials used in its products from a single-supplier; however, equivalent materials are available from other sources or can be produced by the Company, and the Company does not believe it is substantially dependent on any suppliers. The Company uses single-source suppliers in part due to the qualification testing and approval requirements of the Company’s customers, which includes approval of the materials used in a customer’s product. A change in supplier, or the use of multiple suppliers of the same materials, often would necessitate additional qualification testing and approval by customers, which the Company seeks to avoid unless and until the need arises. The Company does not have any contracts with suppliers that impose material binding obligations on the Company or provide the Company with any material rights or benefits.

Securities and Exchange Commission Division of Corporation Finance September 3, 2020 Page 4

The Company has expanded its discussion of the sources and availability of raw materials, including by providing the names of principal suppliers, under the heading “Business – Manufacturing Operations and Principal Suppliers”, on page 10 of Amendment No. 1.

Executive Officer Employment Letters, page 36

Mr. Raymond Li is no longer employed by the Company, effective August 18, 2020. The Company has deleted all references to Mr. Li’s employment throughout Amendment No. 1.

General

The Company has updated its financial statements in Amendment No. 1 to comply with the requirements of Rule 8-08 of Regulation S-X in response to the Staff’s comment.

* * * * *

Securities and Exchange Commission Division of Corporation Finance September 3, 2020 Page 5

We hope the above has been responsive to the Staff’s comments. If you have any questions or require any additional information or documents, please contact the undersigned.

Very truly yours,

/s/ John McIlvery

John McIlvery

cc:     Steven N. Bronson