United States securities and exchange commission logo February 15, 2024 Lisa Gibbs Chief Financial Officer Amtech Systems, Inc. 131 South Clark Drive Tempe, Arizona 85288 Re: Amtech Systems, Inc. Form 10-K for the Fiscal Year Ended September 30, 2023 Filed December 14, 2023 File No. 000-11412 Dear Lisa Gibbs: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Technology