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CORRESP Filing

STEM, INC.
Date: Dec. 9, 2025 · CIK: 0001758766 · Accession: 0001758766-25-000078

Offering / Registration Process

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File numbers found in text: 333-291820

Date
December 9, 2025
Author
Saul R. Laureles
Form
CORRESP
Company
STEM, INC.

Letter

Document December 9, 2025 Via Edgar Only United States Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Attention: Jennifer Angelini SEC Division of Corporation Finance Office of Manufacturing Re: Stem, Inc. Registration Statement on Form S-3 Filed on November 26, 2025 File No. 333-291820 Dear Ms. Angelini: Please be advised that the undersigned is the duly elected Chief Legal Officer and Secretary of Stem, Inc. (the “Registrant”). Having been advised that the Commission has no further comments to the Registrant’s Form S-3 Registration Statement (File No. 333-291820), pursuant to Rules 460 and 461 under the Securities Act of 1933, as amended, the Registrant hereby requests acceleration of the effective date of the Registration Statement on Thursday, December 11, 2025 at 9:00 a.m., or as soon thereafter as practicable. Should you have any questions in regard to this correspondence or any other matter relating to this Registrant’s filing, please do not hesitate to contact me. Very truly yours, /s/ Saul R. Laureles Saul R. Laureles Chief Legal Officer and Secretary Via E-mail: cc: Sarah Dunn, Legal Counsel, Corporate/Securities Eric Scarazzo, Gibson, Dunn & Crutcher LLP

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CORRESP
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 Document December 9, 2025 Via Edgar Only United States Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Attention: Jennifer Angelini SEC Division of Corporation Finance Office of Manufacturing Re:    Stem, Inc.     Registration Statement on Form S-3     Filed on November 26, 2025     File No. 333-291820 Dear Ms. Angelini: Please be advised that the undersigned is the duly elected Chief Legal Officer and Secretary of Stem, Inc. (the “Registrant”). Having been advised that the Commission has no further comments to the Registrant’s Form S-3 Registration Statement (File No. 333-291820), pursuant to Rules 460 and 461 under the Securities Act of 1933, as amended, the Registrant hereby requests acceleration of the effective date of the Registration Statement on Thursday, December 11, 2025 at 9:00 a.m., or as soon thereafter as practicable. Should you have any questions in regard to this correspondence or any other matter relating to this Registrant’s filing, please do not hesitate to contact me. Very truly yours, /s/ Saul R. Laureles Saul R. Laureles Chief Legal Officer and Secretary Via E-mail: cc:    Sarah Dunn, Legal Counsel, Corporate/Securities Eric Scarazzo, Gibson, Dunn & Crutcher LLP