April 7, 2020 Cameron McAulay Chief Financial Officer Transphorm, Inc. 75 Castilian Drive Goleta, CA 93117 Re: Transphorm, Inc. Form 8-K Filed February 14, 2020 File No. 000-55832 Dear Mr. McAulay: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Manufacturing