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 April 8, 2026

Stefan J. Murry
Chief Financial Officer
Applied Optoelectronics, Inc.
13139 Jess Pirtle Blvd.
Sugar Land, Texas 77478

 Re: Applied Optoelectronics, Inc.
 Form 10-K for the Year Ended December 31, 2025
 Filed February 26, 2026
 File No. 001-36083
Dear Stefan J. Murry:

 We have limited our review of your filing 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 Year Ended December 31, 2025
Management s Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 44

1. Please expand your analysis of your results of operations to provide a
more
 comprehensive and quantified discussion and analysis of the underlying
factors that
 contributed to material changes in your results between comparative
periods. Your
 revised disclosure should identify and quantify each material driver of
period-to-period
 changes rather than relying on generalized statements. For example:
 You indicate that the increase in cost of goods sold in 2025 was
primarily
 attributable to higher direct material and direct labor costs
associated with increased
 sales volumes, as well as an increase in inventory reserves. Revise
your disclosure to
 quantify the impact of each of these underlying drivers.
Additionally, discuss
 whether the changes in these components represent known trends or
uncertainties
 reasonably likely to affect future results, and whether these cost
drivers are expected
 to continue, accelerate, or stabilize. Please provide similar
quantitative analysis of
 the underlying factors contributing to changes in your gross margin,
and consider
 April 8, 2026
Page 2

 whether factors mentioned elsewhere in your MD&A, such as product
mix or raw
 material pricing, materially impacted your gross profit and should
be discussed and
 quantified here.
 You also indicate that the increases in sales and marketing expense
were primarily
 due to additional sales efforts for your Quantum Bandwidth products
and higher
 shipping expenses, including tariffs. Revise your disclosure to
quantify the impact of
 each of these underlying drivers, as well as to discuss known trends
or uncertainties
 resulting from increased tariffs, similar to the context provided in
your earnings
 calls.
 This is not meant to represent an all-inclusive list of where your MD&A
could be
 improved. We encourage you to provide quantification of amounts and
further
 clarification throughout your discussion. Refer to Item 303 of
Regulation S-K and
 Section III.B.4 of Release No. 33-8350 for guidance.

Liquidity and Capital Resources
Operating Activities, page 49

2. Please revise future filings to provide a more informative discussion
and analysis of cash
 flows from operating activities, including changes in working capital
components, for the
 periods presented. In doing so, explain the underlying reasons and
implications of
 material changes between periods to provide investors with an
understanding of trends
 and variability in cash flows. Ensure your disclosures are not merely a
recitation of
 changes evident from the face of the financial statements. Consider
quantifying metrics,
 such as Accounts Receivable turnover, Accounts Payable turnover, and
Inventory
 turnover, to facilitate the understanding of material changes in your
working capital.
 Additionally, provide management's insight into why your significant
customer
 Digicomm represented a disproportionately large percentage of your
accounts receivable
 at both December 31, 2025 and 2024, and discuss the implications on your
liquidity. If
 customer concentration creates material credit-risk exposure or affects
the predictability
 of cash flows, your MD&A should clearly describe these risks and whether
they
 represent known trends or uncertainties. See Item 303 of Regulation S-K
and Section
 IV.B of SEC Release No. 33-8350.
Investing Activities, page 49

3. Please revise future filings to provide a more informative discussion
and analysis of cash
 flows from investing activities, including changes in capital
expenditures, for the periods
 presented. In doing so, explain the underlying reasons and implications
of material
 changes between periods to provide investors with an understanding of
trends and
 variability in cash flows. Ensure your disclosures are not merely a
recitation of changes
 evident from the face of the financial statements. Specifically, we note
that your capital
 expenditures quadrupled in 2025. However, your disclosure does not
explain the
 underlying reasons for the significant increase or provide management's
insights into this
 trend. For example, if the higher capital expenditures primarily were
made to expand
 your facilities in China to support your increased production of
internet data center
 products, you expect the new facilities to be fully scaled up by the end
of 2026, and you
 April 8, 2026
Page 3

 believe that this expansion provides adequate production capacity to
meet demand for
 your internet data center products, disclosure of this information would
be consistent
 with the requirements of MD&A. Additionally, while you disclose on page
41 that you
 expect to expand your manufacturing operations in the U.S. and Taiwan in
2026, your
 MD&A disclosures do not provide management's insight into which product
lines will be
 impacted by these planned expansions or whether it is reasonably likely
that the amount
 of capital expenditures in 2026 will materially differ from 2025. If
these investments
 represent part of a multi-period capital plan, or if you expect a
material shift in
 production capacity, cost structure, or geographic concentration, these
should be clearly
 discussed as known trends or uncertainties under Item 303(b)(2). See
Item 303 of
 Regulation S-K and Section IV.B of SEC Release No. 33-8350.
 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 Ernest Greene at 202-551-3733 or Jennifer Thompson at
202-551-3737
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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