Business Description (Item 101)

Company response: The Company acknowledges the Staff’s Comment and respectfully advises the Staff that the Company tracks external research and development expenses on a clinical trial-specific basis while aggregating such expenses for its preclinical studies. The Company undertakes to provide disclosure substantially in the form presented below in its future filings with the Commission. Research and development expenses consist primarily of costs incurred for the discovery and development of our product candidates. Given the number of programs that we have and, because some of our clinical trials may combine more than one program, we track the external research and development costs incurred per clinical… response letter →

Company response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company has revised the disclosure beginning on page 1 of the Form 10-K/A and beginning on page 4 of the Public Filing Form S-3 to address the legal and operational risks associated with having the Company’s revenue generating business in Hong Kong. Additionally, the Company has revised the disclosure beginning on page 13 of the Form 10-K/A to include risk factors related to doing business in Hong Kong. Please note that the Form 10-K/A is incorporated by reference into the Public Filing Form S-3. U.S. Securities and Exchange Commission Division of Corporation Finance Office of Technology If you should… response letter →

Company response: The Company acknowledges the Staff’s comment. In future filings, the Company will provide all of the disclosures required by Item 10(e)(1)(i) of Regulation S-K with respect to any non-GAAP financial measures presented. response letter →

Company response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that management has considered the impact of changes in its business and related end markets, including demand associated with generative AI and the electrification of transportation and infrastructure, in its determination of operating segments and related disclosures. As disclosed in Note 16 to the Company’s fiscal 2025 Annual Report on Form 10-K and Note 13 to the Company’s Quarterly Report on Form 10-Q for the quarter ended November 28, 2025, the Company has concluded that it operates as a single operating and reportable segment. The Company’s Chief Operating Decision Maker (“CODM”) reviews financial… response letter →

Company response: The Company respectfully advises the Staff that the acquisition of Incal Technology did not change the Company’s conclusion that it has one operating segment and one reportable segment. The acquisition of Incal Technology added complementary products that allow the Company to offer a broader range of testing products for both wafer-level and packaged-part burn-in applications. Following the acquisition, Incal’s operations were integrated into the Company’s existing organizational structure, including manufacturing, finance, sales, research and development, and other administrative functions. Consistent with that integration, the Company relocated Incal employees to Aehr’s principal Fremont… response letter →

Company response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that it will enhance its MD&A in future filings, including the Overview section, to provide a more robust discussion of the quality of its earnings and cash flows and the potential variability of its operating results. 5 As disclosed in the Company’s filings, the Company’s business has experienced significant changes in product mix and end-market demand, including reduced near-term demand in certain silicon carbide applications tied to electric vehicle market softness, and increased activity in artificial intelligence, data center, silicon photonics, Gallium Nitride, and packaged-part burn-in applications,… response letter →

Company response: The disclosure referenced on page 37 that states, "We generally sell our products on a spot basis and as such, were exposed to sales prices on our products that decreased faster than the cost of the related raw materials" was intended 1 to convey an aggregated trend at the consolidated level and is reflected in the consolidated net sales and cost of sales explanations, on pages 40 and 41, where we disclose that "Net sales for fiscal 2025 decreased. . .primarily attributed to decreased average selling prices of $381.8 million" and "Cost of sales increased $50.1 million. . .the increase. . .was partially offset by lower input costs of $10.1 million." As the segment discussions are using… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that future annual reports on Form 20-F, including our Annual Report on Form 20-F for the fiscal year ending September 30, 2026, will present managed service renewal rates and 12-month backlog as key performance indicators (until and unless we conclude in the future that such metrics are no longer key performance indicators for our business and cease disclosing them). For the Staff’s reference, here is a markup of the relevant language we expect to include in our future filings (with this language reflecting what would have been included in the Annual Report): Revenue from managed services arrangements is a significant… response letter →

Company response: The Company acknowledges the Staff’s comment and hereby confirms to the Staff that it will include in future periodic reports a qualitative and quantitative discussion of orders and backlog similar in scope to the information included in the Company’s Q4 Fiscal Year 2025 earnings presentations. Johnson Controls, Inc. 5757 N Green Bay Ave, Milwaukee, WI 53209 Segment Analysis, page 35 response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has considered the disclosure requirements of Item 303(b)(2) of Regulation S-K, however, the Company does not track or manage revenue at the individual module level, and its financial systems do not have the capability to identify or allocate revenue by module. Although the Company tracks module usage for operational purposes, and available data indicates that the newsfeed module was the most widely used product during the period, management does not use module-level usage data to assess revenue performance. As noted in the Company’s response to comment 2 above, the Company does not believe user… response letter →

Company response: to prior comment two with a view toward ascertaining the extent to which Biopharmaceuticals and Exemplar continue to constitute two separate operating segments as defined in ASC 280-10-50-1: · Regarding the second bullet, you have told us that you have two separate components or reporting units that were not aggregated under ASC 350-20-35-33 through 35-36. You also appear to indicate that your chief operating decision maker (CODM) continues to receive at least some level of separate discrete financial information for these reporting units. Please tell us what financial information is received by the CODM, and how it changed in the first quarter of 2025 and subsequent periods. · Clarify how… response letter →

Company response: to prior comment 6, including your statements that you do not present GAAP gross profit or GAAP gross margin in your Consolidated Statements of Operations because certain costs related to contract revenues are expensed as incurred and included in research and development expenses and it is not practicable to allocate such expenses to cost of sales. We also note you now believe the adjusted non-GAAP gross profit and adjusted non-GAAP gross margin measures you present should be categorized as Key Performance Metrics (KPMs) because: (1) they are consistent with how you reflect your business in internal financial statements; (2) they are consistent with how your leadership and Chief Executive… response letter →

Company response: The Company refers the Staff to its response to Comment 5 contained herein concluding there is no VIE. response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that the percentage increase in the number of spend customers generating over $1 million in contribution ex-TAC and the contribution ex-TAC across the Company’s top 100 customers are not key performance measures used by management to manage the business within the meaning of Item 303 of Regulation S-K and Commission Release No. 33-10751. The Company’s key performance measures are disclosed in “ Management’s Discussion and Analysis of Financial Condition and Results of Operations—Key Operating and Financial Performance Measures ” sections of its periodic reports. These measures are used by management to manage… response letter →

Company response: In response to the Staff’s comment, the Company respectfully undertakes to revise the relevant disclosure in its future Form 20-F filings as follows (with deletions shown in strikethrough and additions in underline showing the changes against the disclosure in the 2024 Form 20-F), subject to such updates and adjustments to be made in connection with any material developments of the subject matter being disclosed. “ D. Risk Factors … Risks Related to Doing Business in China Changes in China’s economic, political or social conditions or government policies could have a material adverse effect on our business and operations. We generate substantially all of our revenues from our operations in… response letter →