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                          July 22, 2021

       William Bush
       Chief Financial Officer
       STEM, INC.
       100 California Street
       San Francisco, CA 94111

                                                        Re: STEM, INC.
                                                            Registration
Statement on Form S-1
                                                            Filed July 19, 2021
                                                            File No. 333-257994

       Dear Mr. Bush:

              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 SiSi
Cheng at 202-551-5004 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Manufacturing
       cc:                                              John T. Gaffney, Esq.