Correspondence 0001758766-26-000070 from STEM, INC. (STEM)

STEM, INC.
Date: June 8, 2026 · CIK: 0001758766 · Accession: 0001758766-26-000070

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File numbers found in text: 333-296427

Date

June 8, 2026

Author

Saul R. Laureles

Form

CORRESP

Company

STEM, INC.

Letter

Document June 8, 2026 Via Edgar Only United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attention: Jeff Kauten SEC Division of Corporation Finance Office of Technology Re: Stem, Inc. Registration Statement on Form S-3 Filed on June 2, 2026 File No. 333-296427 Dear Mr. Kauten: 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 not reviewed and will not review the Registrant’s Form S-3 Registration Statement (File No. 333-296427), 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 Wednesday, June 10, 2026 at 5:00 p.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 June 8, 2026 Via Edgar Only United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attention: Jeff Kauten SEC Division of Corporation Finance Office of Technology Re:    Stem, Inc. Registration Statement on Form S-3 Filed on June 2, 2026 File No. 333-296427 Dear Mr. Kauten: 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 not reviewed and will not review the Registrant’s Form S-3 Registration Statement (File No. 333-296427), 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 Wednesday, June 10, 2026 at 5:00 p.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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