United States securities and exchange commission logo
June 29, 2023
Desmond Wheatley
President and Chief Executive Officer
Beam Global
5660 Eastgate Dr.
San Diego, California 92121
Re: Beam Global
Registration
Statement on Form S-3
Filed June 2, 2023
File No. 333-272396
Dear Desmond Wheatley:
We have limited our review of your registration statement to
those issues we have
addressed in our 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 circum-
stances 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.
Registration Statement on Form S-3, filed June 2, 2023
General
1. We note disclosure in
your Form 10-Q filed on May 15, 2023, that "In March 2023, the
Company secured a $ 100
million credit facility with OCI Group to support our working
capital requirements."
Please revise your registration statement to disclose the material
provisions of this
credit facility and file the agreement as an exhibit pursuant to Item
601(b)(10) of
Regulation S-K. Include, without limitation, disclosure of any restrictive
covenants, how the
credit facility has been utilized during the respective reporting periods
(if applicable), and
where those amounts are reported in your financial statements. In
addition, please
confirm that you will revise future filings, including your Form 10-Q for
the quarter ended June
30, 2023, to include this disclosure and exhibit. Finally, please tell
us how you concluded
that you were not required to disclose the credit facility in a filing
on Form 8-K.
Desmond Wheatley
Beam Global
June 29, 2023
Page 2
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
statement.
Please contact Erin Donahue at 202-551-6063 or Jennifer Angelini at
202-551-3047 with
any questions.
Sincerely,
FirstName LastNameDesmond Wheatley
Division of
Corporation Finance
Comapany NameBeam Global
Office of
Manufacturing
June 29, 2023 Page 2
cc: Jeff Pietsch
FirstName LastName