TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo February 10, 2023 Mark McKechnie Chief Financial Officer, Executive Vice President and Treasurer ACM Research, Inc. 42307 Osgood Road, Suite I Fremont, California 94539 Re: ACM Research, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Form 10-Q for Fiscal Quarters Ended September 30, 2022 File No. 001-38273 Dear Mark McKechnie: We have completed our review of your filings. 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. Sincerely, Division of Corporation Finance Office of Technology