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CORRESP
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 filename1.htm

 CORRESP

 Arteris, Inc.
 900 E. Hamilton Ave., Suite 300
 Campbell, CA 95008
 February 19, 2026 VIA EDGAR
 United States Securities and Exchange Commission
 Division of Corporation Finance Office of Manufacturing
 100 F Street, N.E. Washington, D.C. 20549-6010
 Re: Arteris, Inc.
 Registration Statement on Form S-3
 Filed February 12, 2026
 File No. 333-293432 To the
addressee set forth above: In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date
of the Registration Statement on Form S-3 (Registration No. 333-293432) (the “ Registration Statement ”) of Arteris, Inc. (the
“ Company ”). We respectfully request that the Registration Statement become effective as of 4:30 p.m., Washington, D.C. time, on February 23, 2026, or as soon as practicable thereafter, or at such other time thereafter
as our counsel, Freshfields US LLP may request by telephone. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Freshfields US LLP, by calling Phillip Stoup at (415) 400-2199 or Aashim Usgaonkar at (646) 863-1660. Thank you
for your assistance in this matter.

 Very truly yours,

 Arteris, Inc.

 By:

 /s/ Nicholas B. Hawkins

 Nicholas B. Hawkins

 Vice President and Chief Financial Officer

 CC:
 K. Charles Janac, Arteris, Inc.
 Phillip S. Stoup, Freshfields US LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 February 17, 2026

Nick Hawkins
Chief Financial Officer
Arteris, Inc.
900 E. Hamilton Ave., Suite 300
Campbell, CA 95008

 Re: Arteris, Inc.
 Registration Statement on Form S-3
 Filed February 12, 2026
 File No. 333-293432
Dear Nick Hawkins:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Baldwin at 202-551-7172 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

CORRESP
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 filename1.htm

 CORRESP

 Arteris, Inc.
 900 E. Hamilton Ave., Suite 200
 Campbell, CA 95008
 December 22, 2025 VIA EDGAR
 United States Securities and Exchange Commission
 Division of Corporation Finance Office of Manufacturing
 100 F Street, N.E. Washington, D.C. 20549-6010

 Re:
 Arteris, Inc.
 Registration Statement on Form S-3
 Filed December 11, 2025
 File No. 333-292078
 To the addressee set forth above: In accordance with Rule 461
under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on
 Form S-3 (Registration No. 333-292078) (the “ Registration Statement ”) of Arteris, Inc. (the
“ Company ”). We respectfully request that the Registration Statement become effective as of 4:30 p.m., Washington, D.C. time, on December 23, 2025, or as soon as practicable thereafter, or at such other time thereafter
as our counsel, Freshfields US LLP may request by telephone. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Freshfields US LLP, by calling Phillip Stoup at (415) 400-2199 or Aashim Usgaonkar at (646) 863-1660. Thank you
for your assistance in this matter.

 Very truly yours,

 Arteris, Inc.

 By:

 /s/ Nicholas B. Hawkins

 Nicholas B. Hawkins

 Vice President and Chief Financial Officer

 CC:
 K. Charles Janac, Arteris, Inc.
 Phillip S. Stoup, Freshfields US LLP

CORRESP
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CORRESP

 Arteris, Inc.

595 Millich Dr. Suite 200

Campbell, CA 95008

 November 30, 2022

VIA EDGAR AND E-MAIL

United States Securities and Exchange Commission

 Division of
Corporation Finance

 Office of Life Sciences

 100 F Street,
N.E.

 Washington, D.C. 20549-6010

 Attention: Jenny
O’Shanick

Re:
 Arteris, Inc.

Registration Statement on Form S-3

Filed November 9, 2022

File No. 333-268257

To the addressee set forth above:

 In accordance
with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-3 (Registration
No. 333-268257) (the “Registration Statement”) of Arteris, Inc. (the “Company”). We respectfully request that the Registration Statement become effective as
of 4:30 p.m., Washington, D.C. time, on December 2, 2022, or as soon as practicable thereafter, or at such other time thereafter as our counsel, Latham & Watkins LLP may request by telephone. Once the Registration Statement has been
declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Phillip Stoup at (415) 395-8216 or Tess Bloom at (415)
395-8897.

 Thank you for your assistance in this matter.

Very truly yours,

Arteris, Inc.

By:

/s/ K. Charles Janac

K. Charles Janac

President and Chief Executive Officer

CC:
 Nicholas B. Hawkins, Arteris, Inc.

Jack Sheridan, Latham & Watkins LLP

Page Mailliard, Latham & Watkins LLP

Phillip S. Stoup, Latham & Watkins LLP

United States securities and exchange commission logo
November 15, 2022
Paul Alpern
General Counsel
Arteris, Inc.
595 Millich Dr. Suite 200
Campbell, CA 95008
Re:Arteris, Inc.
Registration Statement on Form S-3
Filed on November 9, 2022
File No. 333-268257
Dear Paul Alpern:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Jenny O'Shanick at 202-551-8005 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Page Mailliard

CORRESP
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CORRESP

 Arteris, Inc.

595 Millich Dr. Suite 200

Campbell, CA 95008

 October 22, 2021

VIA EDGAR AND E-MAIL

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549-6010

 Attention:     Asia Timmons-Pierce

  Jay Ingram

  Mindy Hooker

  Kevin Stertzel

Re: Arteris, Inc. Registration Statement on Form S-1 (Registration No. 333-259988)

Ladies and Gentlemen:

 In accordance with Rule
461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-1
(Registration No. 333-259988) (the “Registration Statement”) of Arteris, Inc. (the “Company”). We respectfully request that the Registration Statement
become effective as of 4:00 p.m., Washington, D.C. time, on October 26, 2021, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel,
Latham & Watkins LLP, by calling Phillip Stoup at (415) 395-8216 or Tess Bloom at (650) 470-2169.

Thank you for your assistance in this matter.

Very truly yours,

ARTERIS, INC.

By:

/s/ K. Charles Janac

 K. Charles Janac

 President and Chief Executive Officer

cc:
 Nicholas B. Hawkins, Arteris, Inc.

Jack Sheridan, Esq., Latham & Watkins LLP

Page Mailliard, Esq., Latham & Watkins LLP

Phillip Stoup, Esq., Latham & Watkins LLP

Eric Jensen, Esq., Cooley LLP

Seth Gottlieb, Esq., Cooley LLP

CORRESP
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CORRESP

 October 22, 2021

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Manufacturing

 100 F Street, N.E.

Washington, D.C. 20549

 Attention: Asia Timmons-Pierce

Jay Ingram

Mindy Hooker

Kevin Stertzel

Re:
 Arteris, Inc.

Registration Statement on Form S-1 (File
No. 333-259988)

 Request for Acceleration

Ladies and Gentlemen:

 Pursuant to Rule 460 of the General Rules
and Regulations under the Securities Act of 1933, as amended, we wish to advise that as of the date hereof, approximately 3,683 copies of the Preliminary Prospectus dated October 18, 2021 were distributed to prospective underwriters,
institutional investors and prospective dealers in connection with the above-captioned Registration Statement.

 We wish to advise you that the
participating underwriters have informed us that they have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 4:00 p.m.
Eastern Time, on October 26, 2021 or as soon thereafter as practicable.

 [Signature page follows]

 Very truly yours,

JEFFERIES LLC

 COWEN AND COMPANY, LLC

As representatives of the Underwriters

 JEFFERIES LLC

By:

/s/ Gunjeet Baweja

Name:     Gunjeet Baweja

Title:       Managing Director

 COWEN AND COMPANY, LLC

By:

 /s/ Christopher Weekes

Name:     Christopher Weekes

Title:       Managing Director

 [Signature Page to Arteris, Inc. Acceleration Request]

United States securities and exchange commission logo
August 9, 2021
K. Charles Janac
Chief Executive Officer
Arteris, Inc.
595 Millich Dr. Suite 200
Campbell, CA 95008
Re:Arteris, Inc.
Amendment No. 1 to
Draft Registration Statement on Form S-1
Submitted July 26, 2021
CIK 0001667011
Dear Mr. Janac:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
We will lose sales if we are unable to obtain government authorization to export certain of our
products, page 38
1.We note your response to prior comment 3.  Please revise your disclosures to reflect the
potential consequences reflected in the second paragraph of your response.

 FirstName LastNameK. Charles Janac
 Comapany NameArteris, Inc.
 August 9, 2021 Page 2
 FirstName LastName
K. Charles Janac
Arteris, Inc.
August 9, 2021
Page 2
            You may contact Mindy Hooker at 202-551-3732 or Kevin Stertzel at 202-551-3723 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Asia Timmons-Pierce at 202-551-3754 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

United States securities and exchange commission logo
July 8, 2021
K. Charles Janac
Chief Executive Officer
Arteris, Inc.
595 Millich Dr. Suite 200
Campbell, CA 95008
Re:Arteris, Inc.
Draft Registration Statement on Form S-1
Submitted June 11, 2021
CIK 0001667011
Dear Mr. Janac:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 filed June 11, 2021
Summary, page 1
1.We note your disclosure on page 62 that in recent periods you have structured certain
agreements with customers that include substantial up front licensing payments.  Please
reflect this information in your summary.
2.We note your disclosure that in 2020 you incurred a net loss of $3.3 million.  Please
disclose, if true, that you expect to incur further losses in the short term.  In that regard,
we note your disclosure on page 70.
We will lose sales if we are unable to obtain government authorization to export certain of our
products, page 38

 FirstName LastNameK. Charles Janac
 Comapany NameArteris, Inc.
 July 8, 2021 Page 2
 FirstName LastNameK. Charles Janac
Arteris, Inc.
July 8, 2021
Page 2
3.Please elaborate on the potential consequences related to your business transactions with
Bada and HiSilicon.  Please also disclose the remedial measures that you have adopted.
Our Post-IPO Certificate of Incorporation provides that the Court of Chancery of the State of
Delaware, page 47
4.Please ensure that your disclosure regarding the scope of your exclusive forum provisions
is consistent with your disclosures on page 120.
Unaudited Pro Forma Combined Financial Information For Magillem, page 57
5.We note that the unaudited pro forma combined statement of income (loss) for the year
ended December 31, 2020, is derived from the historical consolidated statement of income
(loss) of the Company for the year ended December 31, 2020 and the historical statement
of operations of Magillem for the period of January 1, 2020 through November 30, 2020,
and gives effect to the Acquisition as if it had occurred on January 1, 2020.  We further
note you have included audited financial statements for Magillem for the year ended June
30, 2020 in this S-1 filing.  Please revise your pro forma disclosure to clarify that
Magillem's fiscal year end is June 30 and explain how your presentation complies
with 11-02(c)(3) of Regulation S-X.
6.Regarding Footnote 3(a) on page 59, please revise your filing to provide a more
comprehensive explanation of how the adjustment was calculated.
7.In reference to Footnote 3(c) on page 60, please explain why your adjustment appears to
be adding additional transaction costs in the pro forma income statement rather than
removing the incremental non-recurring transaction costs related to the acquisition which
are reflected in the historical income statement.
Non-U.S. GAAP Financial Measures, page 66
8.We note your reconciliation of Net Income and EPS on page 67.  Please revise the lines
"Non-U.S. net income (loss)" and "Non-U.S. EPS" to specifically identify these items as
Non-GAAP net income and Non-GAAP EPS.
Report of Independent Registered Public Accounting Firm, page F-2
9.We note Arteris was formed in 2004 and the current auditor was engaged in 2020. Please
confirm that Arteris did not change auditors during its two most recent fiscal years or
subsequent interim period; alternatively, please provide the disclosures required by Item
304 of Regulation S-K, including a letter from the former auditors, filed as an exhibit to
the registration statement.
Arteris Inc. and Subsidiaries - Notes to the Consolidated Financial Statements
8. Acquisition, page F-22

 FirstName LastNameK. Charles Janac
 Comapany NameArteris, Inc.
 July 8, 2021 Page 3
 FirstName LastName
K. Charles Janac
Arteris, Inc.
July 8, 2021
Page 3
10.Please disclose the amounts of revenue and earnings of Magillem since the acquisition
date included in the consolidated income statement for the December 31, 2020 reporting
period.  Refer to ASC Topic 805-10-50-2h1.
General
11.We note that you intend to provide current financial information in a future amendment.
Please be advised that we will need sufficient time to review this information and may
have additional comments when this information is provided.
            You may contact Mindy Hooker at 202-551-3732 or John Cash at 202-551-3768 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Asia Timmons-Pierce at 202-551-3754 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing