Washington, DC 20549



Specialized Disclosure Report



(Exact name of registrant as specified in its charter)


DELAWARE   001-36083   76-0533927
(State or other jurisdiction of incorporation)   (Commission File Number)  

(IRS Employer

Identification No.)


13139 Jess Pirtle Blvd.

Sugar Land, TX 77478

(Address of principal executive offices, including zip code)


David Kuo, General Counsel and Secretary

(281) 295-1800

(Name and telephone number, including area code, of the person to contact in connection with this report.)


Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:



  [X] Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017.

















Section 1 - Conflict Minerals Disclosure


Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibit


This Form SD of Applied Optoelectronics, Inc. (the “Company”) is filed pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1, 2017 to December 31, 2017.


Certain Conflict Minerals (as defined in paragraph (d)(3) of Item 1.01) are necessary to the functionality or production of certain products manufactured by the Company. We conducted in good faith a Reasonable Country of Origin Inquiry (RCOI) on the source of our Conflict Minerals for 2017. Based on the responses to our RCOI, we have reason to believe that, during the period covered by this report, certain of such Conflict Minerals likely originated in the Democratic Republic of the Congo (the “DRC”) and/or one or more of the countries that share an internationally recognized border with the DRC. Accordingly, the Company has prepared a Conflict Minerals Report, a copy of which is attached hereto as Exhibit 1.01. The Conflict Minerals Report is also publicly available on the Company’s website at http://ao-inc.com/about-our-company/global-compliance. The Company is filing its Conflict Minerals Report for the reporting period January 1, 2017 to December 31, 2017 as Exhibit 1.01 to this report as required by Item 1.01.


Section 2 – Exhibits


Item 2.01 Exhibits


Exhibit 1.01 – Conflict Minerals Report for the reporting period January 1, 2017 to December 31, 2017 as required by Items 1.01 and 1.02 of this Form.





Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.




  By:  /s/ David C. Kuo                            
    David C. Kuo
    General Counsel and Secretary


Date:  May 30, 2018