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