0001493152-21-008324.txt : 20210510 0001493152-21-008324.hdr.sgml : 20210510 20210408192245 ACCESSION NUMBER: 0001493152-21-008324 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20210408 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Stem Holdings, Inc. CENTRAL INDEX KEY: 0001697834 STANDARD INDUSTRIAL CLASSIFICATION: MEDICINAL CHEMICALS & BOTANICAL PRODUCTS [2833] IRS NUMBER: 611794883 STATE OF INCORPORATION: NV FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 2201 NW CORPORATE BVD STREET 2: SUITE 205 CITY: BOCA RATON STATE: FL ZIP: 33431 BUSINESS PHONE: 561-948-5410 MAIL ADDRESS: STREET 1: 2201 NW CORPORATE BVD STREET 2: SUITE 205 CITY: BOCA RATON STATE: FL ZIP: 33431 CORRESP 1 filename1.htm

Stem Holdings, Inc.

2201 NW Corporate Blvd., Suite 205

Boca Raton, FL 33431

April 8, 2021

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Office of Life Sciences

	Re:	Stem Holdings, Inc.
		Registration on Form S-1/A (6^th Amendment)
		File No. 333-251897
		Filed on April 5, 2021

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Stem Holdings, Inc. (the “Registrant”), hereby requests that the effectiveness under the Securities Act of 1933, as amended, of the above-captioned Registration Statement be accelerated to 9:30 a.m., Eastern time, on April 12, 2021, or as soon thereafter as practicable. In connection with the foregoing request for acceleration of effectiveness, the Registrant hereby acknowledges the following:

	●	should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

	●	the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

	●	the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact Robert L. B. Diener, Esq. of the Law Offices of Robert Diener at (808) 573-6163 (facsimile (310) 362-8887) with any questions you may have. In addition, please notify Mr. Diener when this request for acceleration has been granted.

Very truly yours,

STEM HOLDINGS, INC.

By:	/s/ Adam Berk
	Adam Berk
	Chief Executive Officer

cc:	Robert L. B. Diener, Esq.