**EXHIBIT
        14.1**
 
 **CLEARONE
        CODE OF ETHICS**
   As
        a
        leading global provider of premium audio conferencing systems and other related
        products for audio, video and web conferencing ClearOne is committed to
        excellence in accordance with the highest ethical standards.
  ClearOne
        recognizes that it is each officer, director, and employee’s responsibility to
        act in accordance with the Company’s standards as set forth in the Code of
        Ethics and Employee Handbook. The purpose of the Code of Ethics is to establish
        those standards and to summarize some of the important rules that govern
        the
        Company in the proper conduct of its business.
  **Ethics**
  To
        our
        employees we are committed to honesty, just management, fairness, providing
        a
        safe and healthy environment free from the fear of retribution, and respecting
        the dignity due each of us.
  To
        our
        customers we are committed to produce quality products and services that
        are
        reliable and are delivered effectively and efficiently, at a fair
        price.
  To
        the
        communities in which we live and work we are committed to observe sound business
        practices and to be concerned and responsible citizens.
  To
        our
        shareholders we are committed to pursuing sound growth and earnings, and
        to
        exercise prudence in the use of our assets and resources.
  To
        our
        suppliers and partners we are committed to fair dealings and the sense of
        responsibility required of good business relationships.
  **Legal**
  We
        will
        conduct our business in accordance with all applicable laws and regulations
        of
        the various Municipalities, States, Federal Governments, Government Agencies,
        International Authorities, and all others that regulate our activities.
  **Work
        Environment**
  Employees
        will have a workplace where they feel respected and appreciated. We respect
        cultural diversity; we do not tolerate harassment or discrimination of any
        kind
        most specifically with respect to race, color, religion, gender, age, national
        origin, disability and veteran or marital status.
  Providing
        an environment that supports honesty, integrity, respect, trust, responsibility,
        and citizenship provides us with the opportunity to achieve excellence in
        our
        workplace. While everyone who works for the Company must contribute to the
        creation and maintenance of such an environment, our executives and management
        personnel assume special responsibility for fostering a work environment
        that is
        free from the fear of retribution and will bring out the best in everyone.
  **Environment**
  We
        are
        committed to providing a drug-free, safe and healthy work environment, and
        to
        observe environmentally sound business practices. Each of us is responsible
        for
        compliance with environment, health, and safety laws and
        regulations.
  1
   **Corporate**
  We
        will
        maintain complete and accurate Company records, including all financial records
        and documentation. Accurate records and verification of facts are the
        responsibility and duty of our entire organization.
  **Confidentiality**
  ClearOne
        requires its employees to keep confidential Company information including
        business strategies, pending contracts, new products, research, financial
        projections, customer lists and other sensitive matters. Confidential
        information may not be shared or released without proper authority to anyone
        not
        employed by the Company or to an employee who has no need for such
        information.
 
 Proprietary
        Company information may not be disclosed to anyone without proper authorization,
        and proprietary documents will be protected and secure.
 In
        the
        course of normal business activities, suppliers, customers and competitors
        may
        sometimes divulge to Company employee’s information that is proprietary to their
        business. ClearOne requires its employees to respect these
        confidences.
  **Political
        Activities**
  ClearOne
        encourages its employees to become involved in civic affairs and to participate
        in the political process. Employees must however, understand that their
        involvement and participation must be on an individual basis, on their own
        time,
        and at their own expense. In the United States, federal law prohibits
        corporations from donating corporate funds, goods, or services, directly
        or
        indirectly, to candidates of federal offices. This includes employees’ work
        time.
  
 **Conflict
        of Interest**
  ClearOne
        does not seek to gain advantage through improper use of business contacts
        or
        investments. Good judgment and moderation must be exercised. Employees should
        avoid any situation that might involve a conflict of interest between their
        personal interests and the interests of the Company. In dealing with customers,
        suppliers or competitors, employees should act in the best interest of the
        Company to the exclusion of personal advantage.
  **Gifts
        or Favors**
  The
        sale
        of Company products and services should always be free from even the perception
        that favorable treatment was sought, received, or given in exchange for the
        furnishing or receipt of business courtesies. Employees will neither give
        nor
        accept business courtesies that constitute, or could be reasonable perceived
        as
        constituting, unfair business inducements or that would violate laws,
        regulations or policies of the Company or customer, or could cause embarrassment
        to or reflect negatively on the Company’s reputation.
  Employees
        of the federal Legislative, Executive, and Judiciary Branches of government,
        and
        employees of state and local government departments or agencies are subject
        to a
        wide variety of laws and regulations. These laws and regulations and Corporate
        Policy Statements pertaining to them must be consulted prior to offering
        such
        employees anything of value.
   2
  **Business
        Courtesies**
  It
        is an
        acceptable practice for ClearOne employees to provide meals, refreshments,
        entertainment, and other business courtesies of reasonable value to persons
        in
        support of business activities, provided:
 
 -
        The
        practice does not violate any law or regulation or the standards of conduct
        of
        the recipient’s organization. It is the employee’s responsibility to inquire
        about prohibitions or limitations of the recipient’s organization before
        offering any business courtesy; and
  -
        The
        business courtesy must be consistent with marketplace practices, infrequent
        in
        nature, and may not be lavish or extravagant. While it is difficult to define
        “lavish or extravagant” by means of a specific dollar amount, a common sense
        determination should be made consistent with reasonable marketplace practices.
  **Company
        Assets**
  Proper
        use of Company and customer property, electronic communications systems,
        information resources, material, facilities, and equipment is the responsibility
        of each employee. All employees must use and maintain these assets with the
        utmost care and respect, guarding against waste and abuse, and never borrow
        or
        remove them from Company property without management’s permission. Employees
        must be cost-conscious and alert to opportunities for improving performance
        while reducing costs.
  All
        employees are responsible for complying with the requirement of software
        copyright licenses related to software packages used in fulfilling job
        requirements.
  **Insider
        Trading**
  In
        our
        role as a publicly owned company, we must always be alert to and comply with
        security laws and regulation of the United States and other countries.
  It
        is
        against the law for employees to buy or sell Company stock based on material,
        non-public “insider” information about or involving the Company. Employees must
        not trade in the securities of ClearOne when they are aware of information
        affecting the Company’s business that has not been publicly released or in
        situations where trading would call their judgment into question. This includes
        all varieties of stock trading such as options, puts and calls, straddles,
        selling short, etc. Two rules can help protect employees in this area: (1)
        do
        not use non-public information for personal gain (2) do not pass along such
        information to someone else who has no need to know.
  This
        guidance also applies to the securities of other companies (suppliers, vendors,
        subcontractors, etc.) for which employees receive information in the course of
        employment at ClearOne.
  **ClearOne
        Executives and Directors**
  Senior
        Executive Officers and Directors of ClearOne must:
  -Act
        with
        honesty and integrity, avoiding actual or apparent conflicts of interest
        in
        personal and professional relationships.
 
 -Provide
        colleagues with information that is accurate, complete, objective, relevant,
        timely and understandable.
 
 -Comply
        with applicable laws, rules, and regulations for federal, state, and local
        governments and other appropriate private and public agencies.
  3
  
 -Take
        all
        steps reasonably necessary to cause the disclosure in the Company’s periodic
        reports to be full, fair, accurate, timely and understandable and to become
        familiar with the disclosure requirement applicable to the Company as well
        as
        the business and financial operations of the Company.
 
 -Act
        in
        good faith, with due care, competence, and diligence, without misrepresenting
        material facts or allowing independent judgment to be subordinated.
 
 -Respect
        the confidentiality of information acquired in the course of
        employment.
 
 -Share
        knowledge and maintain skills necessary and relevant to the company’s
        needs.
 
 -Proactively
        promote ethical and honest behavior within the workplace.
 
 -Assure
        responsible use and control of all assets, resources, and information in
        possession of the Company.
  **Accountability**
  Senior
        Executive Officers of ClearOne are to comply with this Code of Ethics and
        should
        report to the Board of Directors any evidence they become aware of that is
        in
        conflict with the intent of this Code of Ethics.
 
 The
        Board
        of Directors shall upon receiving relevant information of a conflict take
        appropriate action, taking into account the nature and severity of the
        violation, whether the violation appears to have been intentional or
        inadvertent, whether the individual in question had been advised prior to
        the
        violation as to the proper course of action and whether or not the individual
        in
        question had committed other violations in the past.
  4