February
8, 2019
By EDGAR
Securities and
Exchange Commission
Division of
Corporation Finance
100 F.
Street, N.E.
Washington, D.C.
20549
Attention: Michael
Fay
Amanda Ravitz
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Re:
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ACM Research, Inc.
Registration Statement on Form S-3
File No. 333-228734
Request for Acceleration
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Ladies
and Gentlemen:
Pursuant
to Rule 461 under the Securities Act of 1933, as amended, ACM
Research, Inc. (the “Registrant”) hereby requests
acceleration of the effective date of the above-referenced
Registration Statement on
Form S-3 (File No. 333-228734) (as
amended, the “Registration
Statement”), so that it may become effective at 5:00
p.m. Eastern time on February 12, 2019, or as soon thereafter as
practicable.
Please
do not hesitate to contact our legal counsel, Mark L. Johnson, at
(617) 261-3260, if you have any questions or would like
additional information regarding this matter.
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Sincerely,
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ACM Research, INC.
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By:
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/s/ David H.
Wang
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David H.
Wang
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Chief
Executive Officer and President
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