August 11, 2021

VIA EDGAR

United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549 

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

Ladies and Gentlemen:

Stem, Inc., a Delaware corporation (the “Company”), respectfully requests pursuant to Rule 461 under the Securities Act of 1933, as amended, that the effective date of the Company’s Registration Statement on Form S-1 (File No. 333-257994) be accelerated and that it be declared effective on August 12, 2021 at 12:00 p.m. Eastern time, or as soon as practicable thereafter.

Please contact John Gaffney of Gibson, Dunn & Crutcher LLP at (212) 351-2626 as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

Very truly yours,
STEM, INC.
By:	/s/ Saul Laureles
	Name:	Saul Laureles
	Title:	Chief Legal Officer and Secretary

cc: Evan D’Amico

Gibson, Dunn & Crutcher LLP

cc: John Carrington
Chief Executive Officer, Stem, Inc. William Bush Chief Financial Officer, Stem, Inc.