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 March 17, 2026

Chris Siu
Chief Financial Officer
Aehr Test Systems, Inc.
400 Kato Terrace
Fremont, CA 94539

 Re: Aehr Test Systems, Inc.
 Form 10-K for the Fiscal Year Ended May 30, 2025
 Form 10-Q for the Three and Six Months Ended November 28, 2025
 File No. 000-22893
Dear Chris Siu:

 We have limited our review of your filings to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended May 30, 2025
Item 7. Management s Discussion and Analysis of Financial Condition and
Results of
Operations
Critical Accounting Policies and Estimates, Income Taxes, page 24

1. We note your disclosure that you released a valuation allowance of $21.9
Million during
 the fiscal year ended May 31, 2024, based on your conclusion that it is
more likely than
 not that your deferred tax assets will be realized. However, we see that
you
 reported pretax losses in the fiscal year ended May 30, 2025, which
continue through the
 six months ended November 28, 2025. Please update your Critical
Accounting Policy in
 future filings to inform investors of your continued assessments of your
valuation
 allowance in light of these losses and provide more transparent
disclosure regarding the
 specific factors and estimates that impact your judgment in this area,
including the
 assessment of recent operating performance. In this regard, as needed,
provide an
 updated critical accounting policy for income taxes in your quarterly
reports. Refer to
 SEC Release 33-8350 and revise to provide greater insight into the
quality and variability
 of information regarding financial condition and operating performance.
 March 17, 2026
Page 2

Results of Operations, Discussion of Results of Operations, page 25

2. Throughout the discussion of results of operations, you indicate that
 multiple factors contributed to a material change in your results.
Please revise future
 filings to quantify the impact of each material factor identified. Refer
to Item 303(b)(2)
 of Regulation S-K and SEC Release No. 33-8350.
Revenue, page 25

3. Refer to the disclosure on page 12 that you derive a substantial portion
of net sales from
 the sale of a relatively small number of systems with high dollar value.
In that regard,
 please revise future filings to provide a more detailed quantified
analysis of the drivers of
 fluctuations in your revenue, including the changes in the the number
and type of
 systems sold and the impact of any changes in price ranges of systems
sold during each
 period presented. Reference Item 303(b)(2) of Regulation S-K and SEC
Release No. 33-
 8350.
Form 10-Q for the Three and Six Months Ended November 28, 2025
Financial Statements
Note 13. Segment and Concentration Information, page 19

4. We see your discussion in MD&A that the rapid advancement of generative
artificial
 intelligence (AI) and the accelerating electrification of transportation
and global
 infrastructure represent two of the most significant macro-trends
impacting the
 semiconductor industry today. These appear to represent two different
end markets for
 your products as well, one with decreasing sales, and one with
increasing sales, based on
 your reporting. Tell us how the changes in your business and related end
markets impact
 how management reviews the business, your determination of operating
segments, and
 all other general segment disclosures, including revenue by end market.
5. In this regard, tell us how the acquisition of Incal Technology impacted
your business
 segments and related disclosures.
Item 2. Management s Discussion and Analysis of Financial Condition and
Results of
Operations, page 20

6. We see that you include only a short Overview in MD&A that focuses
primarily on your
 products. In light of the significant changes to your business and the
end markets for
 your products, revise your discussion in future filings to provide
information about the
 quality of, and potential variability of, the company's earnings and
cash flow, so that
 investors can ascertain the likelihood that past performance is
indicative of future
 performance. Identify and disclose known trends, events, demands,
commitments and
 uncertainties that are reasonably likely to have a material effect on
financial condition or
 operating performance.
 March 17, 2026
Page 3

 In closing, 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.

 Please contact Kristin Lochhead at 202-551-3664 or Julie Sherman at
202-551-3640 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
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