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SEC Company Response from APPLIED OPTOELECTRONICS, INC. (AAOI) (CIK 0001158114) (AAOI) — Sep 20, 2013

APPLIED OPTOELECTRONICS, INC. (AAOI) (CIK 0001158114)
Date: Sept. 20, 2013 · CIK: 0001158114 · Accession: 0001104659-13-071434

Offering / Registration Process Regulatory Compliance Financial Reporting

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File numbers found in text: 333-190591

Date
September 20, 2013
Author
Frank Wu
Form
CORRESP
Company
APPLIED OPTOELECTRONICS, INC. (AAOI) (CIK 0001158114)

Letter

DLA Piper LLP (US)

1000 Louisiana Street, Suite 2800 Houston, Texas 77002-5005

www.dlapiper.com

Frank Wu

frank.wu@dlapiper.com

T 713.425.8446

F 713.300.6046

September 20, 2013

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Russell Mancuso

Tom Jones

Praveen Kartholy

Gary Todd

Re: Amendment No. 3 to Registration Statement on Form S-1 for Applied Optoelectronics, Inc.

Filed on September 20, 2013

Registration Statement No. 333-190591

Ladies and Gentlemen:

We are submitting this letter on behalf of Applied Optoelectronics, Inc. (the “Company”) to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) as a courtesy to the Staff in connection with the Company’s Registration Statement publicly filed on August 13, 2013 (the “Registration Statement”). The Company is concurrently filing Amendment No. 3 to the Registration Statement (“Amendment No. 3”). For the convenience of the Staff, we are providing by overnight delivery to the Staff a copy of this letter and four marked copies of Amendment No. 3 (against Amendment No. 2 to the Registration Statement filed on September 11, 2013).

If you should have any questions regarding the above or the Registration Statement, please do not hesitate to call the undersigned at (713) 425-8446.

Very truly yours,
DLA Piper LLP (US)

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CORRESP
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DLA Piper LLP (US)

1000 Louisiana Street, Suite 2800
   Houston, Texas  77002-5005

www.dlapiper.com

Frank Wu

frank.wu@dlapiper.com

T   713.425.8446

F   713.300.6046

September 20, 2013

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:      Russell Mancuso

Tom Jones

Praveen Kartholy

Gary Todd

Re:          Amendment No. 3 to Registration Statement on Form S-1 for Applied Optoelectronics, Inc.

Filed on September 20, 2013

Registration Statement No. 333-190591

Ladies and Gentlemen:

We are submitting this letter on behalf of Applied Optoelectronics, Inc. (the “Company”) to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) as a courtesy to the Staff in connection with the Company’s Registration Statement publicly filed on August 13, 2013 (the “Registration Statement”).  The Company is concurrently filing Amendment No. 3 to the Registration Statement (“Amendment No. 3”). For the convenience of the Staff, we are providing by overnight delivery to the Staff a copy of this letter and four marked copies of Amendment No. 3 (against Amendment No. 2 to the Registration Statement filed on September 11, 2013).

If you should have any questions regarding the above or the Registration Statement, please do not hesitate to call the undersigned at (713) 425-8446.

Very   truly yours,

DLA   Piper LLP (US)

/s/   Frank Wu

Frank   Wu

Partner

cc:           Chi-Hsiang (Thompson) Lin (Applied Optoelectronics, Inc.)

James L. Dunn, Jr. (Applied Optoelectronics, Inc.)

Philip Russell (DLA Piper LLP (US))

J. Robert Suffoletta (Wilson Sonsini Goodrich & Rosati, Professional Corporation)