May 30, 2025 Scott Bibaud Chief Executive Officer Atomera Inc. 750 University Ave., Suite 280 Los Gatos, CA 95032 Re: Atomera Inc. Registration Statement on Form S-3 Filed May 27, 2025 File No. 333-287603 Dear Scott Bibaud: 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 Kristin Baldwin at 202-551-7172 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing