(null)

Needham Growth Fund
Schedule of Investments
March 31, 2022 (Unaudited)
	Shares		Fair Value
Common Stocks (97.8%)
Aerospace & Defense (1.8%)
Parsons Corp. (a)		77,500	$	2,999,250
Biotechnology (1.8%)
G1 Therapeutics, Inc. (a)		80,000		608,000
Gilead Sciences, Inc.		41,000		2,437,450
				3,045,450
Capital Markets (0.4%)
Coinbase Global, Inc. - Class A (a)		3,500		664,510
Chemicals (7.5%)
Aspen Aerogels, Inc. (a)		367,000		12,654,160
Commercial Services & Supplies (1.6%)
ACV Auctions, Inc. - Class A (a)		100,000		1,481,000
Clean Harbors, Inc. (a)		10,700		1,194,548
				2,675,548
Communications Equipment (5.7%)
ADTRAN, Inc.		130,000		2,398,500
Cambium Networks Corp. (a)		88,850		2,100,414
KVH Industries, Inc. (a)		500,000		4,550,000
ViaSat, Inc. (a)(c)		12,500		610,000
				9,658,914
Diversified Consumer Services (0.1%)
Bright Horizons Family Solutions, Inc. (a)		1,500		199,035
Diversified Telecommunication Services (0.1%)
IHS Holding, Ltd. (a)		11,572		128,218
Electrical Equipment (3.1%)
Vicor Corp. (a)		73,500		5,185,425
Electronic Equipment, Instruments & Components (3.6%)
Arlo Technologies, Inc. (a)		40,000		354,400
Corning, Inc.		32,500		1,199,575
FARO Technologies, Inc. (a)		7,500		389,400
II-VI, Inc. (a)		30,000		2,174,700
Vishay Intertechnology, Inc.		66,050		1,294,580
Vishay Precision Group, Inc. (a)		20,400		655,860
				6,068,515
Entertainment (0.1%)
World Wrestling Entertainment, Inc. - Class A		3,500		218,540
Health Care Equipment & Supplies (5.5%)
Becton Dickinson & Co.		19,000		5,054,000
CryoPort, Inc. (a)		42,500		1,483,675
Medtronic PLC (Ireland)		20,000		2,219,000
ViewRay, Inc. (a)		144,780		567,538
				9,324,213
Health Care Providers & Services (2.2%)
Laboratory Corp. of America Holdings (a)		11,250		2,966,175
Quest Diagnostics, Inc.		5,500		752,730
				3,718,905

Hotels, Restaurants & Leisure (0.8%)
Vacasa, Inc. - Class A (a)	161,950	1,339,326
Industrial Conglomerates (0.3%)
Honeywell International, Inc.	2,500	486,450
Interactive Media & Services (0.4%)
Alphabet, Inc. - Class A (a)	250	695,337
IT Services (3.1%)
Akamai Technologies, Inc. (a)(c)	33,500	3,999,565
BigCommerce Holdings, Inc. (a)	60,000	1,314,600
		5,314,165
Life Sciences Tools & Services (7.2%)
Bruker Corp.	5,000	321,500
Fluidigm Corp. (a)	40,000	143,600
Thermo Fisher Scientific, Inc.	20,000	11,813,000
		12,278,100
Media (2.9%)
Comcast Corp. - Class A	104,000	4,869,280
Oil, Gas & Consumable Fuels (0.6%)
Chevron Corp.	5,000	814,150
Navigator Holdings, Ltd. (a)	20,000	244,200
		1,058,350
Equity Real Estate Investment Trusts (REITs) (0.4%)
American Tower Corp.	2,500	628,050
Semiconductors & Semiconductor Equipment (33.3%) (d)
Allegro MicroSystems, Inc. (a)	15,000	426,000
Analog Devices, Inc.	10,000	1,651,800
Applied Materials, Inc.	9,000	1,186,200
ASML Holding NV - ADR	1,500	1,001,895
AXT, Inc. (a)	400,000	2,808,000
Entegris, Inc.	101,000	13,257,260
FormFactor, Inc. (a)	127,500	5,358,825
Lam Research Corp.	2,500	1,344,025
Marvell Technology, Inc.	12,500	896,375
MKS Instruments, Inc.	25,000	3,750,000
NeoPhotonics Corp. (a)	62,500	950,625
Nova, Ltd. (a)	47,500	5,171,800
PDF Solutions, Inc. (a)	407,600	11,359,812
Photronics, Inc. (a)	107,850	1,830,214
SiTime Corp. (a)	12,500	3,097,750
SkyWater Technology, Inc. (a)	22,850	247,466
Taiwan Semiconductor Manufacturing Co., Ltd. (Taiwan) - ADR	9,000	938,340
Teradyne, Inc.	2,500	295,575
Veeco Instruments, Inc. (a)	35,000	951,650
		56,523,612
Software (7.2%)
The Trade Desk, Inc. - Class A (a)	47,500	3,289,375
Alteryx, Inc. - Class A (a)	35,000	2,503,550
Appian Corp. (a)	2,500	152,050
ChannelAdvisor Corp. (a)	35,000	579,950
Copperleaf Technologies, Inc. (a)	13,600	176,017
Coupa Software, Inc. (a)	2,500	254,075
Datadog, Inc. - Class A (a)	1,500	227,205
Duck Creek Technologies, Inc. (a)	10,000	221,200
Q2 Holdings, Inc. (a)	16,500	1,017,225
Sumo Logic, Inc. (a)	50,000	583,500
Telos Corp. (a)	300,000	2,991,000
WANdisco PLC (a)	75,000	292,615
		12,287,762

Specialty Retail (4.0%)
CarMax, Inc. (a)	70,000		6,753,600
Technology Hardware, Storage & Peripherals (3.8%)
Apple, Inc.	10,500		1,833,405
Intevac, Inc. (a)	273,600		1,463,760
Super Micro Computer, Inc. (a)	80,000		3,045,600
Western Digital Corp. (a)	2,500		124,125
			6,466,890
Textiles, Apparel & Luxury Goods (0.2%)
Allbirds, Inc. - Class A (a)	62,500		375,625
Trading Companies & Distributors (0.2%)
Air Lease Corp.	7,500		334,875
Total Common Stocks
(Cost $70,669,378)		$	165,952,105

Short-Term Investments (2.4%)
Money Market Fund (2.4%)
Dreyfus Treasury Securities Cash Management - Institutional Class, 0.11% (b)
Total Short-Term Investments
(Cost $4,082,309)	4,082,309		4,082,309

Total Investments (100.2%)
(Cost $74,751,687)			170,034,414
Liabilities in Excess of Other Assets (-0.2%)			(288,856	)
Net Assets (100.0%)		$	169,745,558

	Percentages are stated as a percent of net assets.
	Industry classifications may be different than those used for compliance monitoring purposes.
(a)	Non-income producing security.
(b)	Rate shown is the seven-day yield as of March 31, 2022.
(c)	Security position is either entirely or partially held in a segregated account as collateral for securities sold short, aggregating a total market value of $1,261,425.
(d)	As of March 31, 2022, the Fund had a significant portion of its assets invested in the Semiconductors & Semiconductor Equipment industry.
ADR	American Depositary Receipt
	The Global Industry Classification Standard (GICS^®) was developed by and/or is the exclusive property of MSCI, Inc. and Standard & Poor's Financial Services LLC (“S&P”).

	Distribution of investments by country or territory of incorporation, as a percentage of Total Investments, is as follows (Unaudited):
	Country	Long
	United States^	92.8%
	Israel	3.0%
	Cayman Islands	1.3%
	Ireland	1.3%
	Netherlands	0.6%
	Taiwan	0.6%
	Jersey	0.2%
	Canada	0.1%
	Marshall Islands	0.1%
	Total	100.0%

^	United States allocation includes Short-Term Investment-Money Market Fund of 2.4%

Needham Funds

Notes to Schedule of Investments (Unaudited)

March 31, 2022

Organization

Needham Growth Fund (“NGF”), Needham Aggressive Growth Fund (“NAGF”) and Needham Small Cap Growth Fund (“NSCGF”) (each, a “Portfolio” and collectively, the “Portfolios”), are portfolios of The Needham Funds, Inc. (the “Company”), which is registered under the Investment Company Act of 1940, as amended (the “1940 Act”), as a diversified, open-end management investment company. The Company was organized as a Maryland corporation on October 12, 1995. NGF, NAGF, and NSCGF each currently offer two classes, the Retail Class and the Institutional Class. The Institutional Class commenced operations on December 30, 2016.

Each Portfolio is an investment company and accordingly follows the investment company accounting and reporting guidance of the Financial Accounting Standards Board (“FASB”) Accounting Standards Codification Topic 946 “Financial Services – Investment Companies.”

2.	Significant Accounting Policies

The following is a summary of significant accounting policies followed by the Company in the preparation of its financial statements. These policies are in conformity with accounting principles generally accepted in the United States of America (“GAAP”).

Security Valuation: Portfolio securities for which market quotations are readily available are stated at the last sale price reported by the principal exchange for the security as of the exchange’s close of business. Securities for which no sale has taken place during the day and securities which are not listed on an exchange are valued at the mean of the highest closing bid and lowest asked prices. Exchange traded options are valued at the last reported sale price on any exchange on which the option is principally traded. If no sales are reported on a particular day, the options will be valued at the mean between the highest closing bid and lowest asked prices across the exchanges where the option is traded. Non-exchange traded options will also be valued at the mean between the last bid and asked quotations. For options where market quotations are not readily available, value will be determined in accordance with the fair value procedures described below. All other securities and assets for which (a) market quotations are not readily available, such as in the case of a market or technical disruption that prevents the normal trading of a security held by a Portfolio, (b) market quotations are believed to be unrepresentative of fair market value, such as in the case of a thinly traded security, or (c) valuation is normally made at the last sale price on a foreign exchange and a significant event occurs after the close of that exchange but before the New York Stock Exchange closes, are valued at their fair value as determined in good faith by the Board of Directors (the “Board”) in accordance with Fair Value Procedures established by the Board. The Company’s Fair Value Procedures are implemented and monitored by a Fair Value Committee (the “Committee”) designated by the Board. When a security is valued in accordance with the Fair Value Procedures, the Committee determines a value after taking into consideration any relevant information that is reasonably available to the Committee. Some of the more common reasons that may necessitate that a security be valued pursuant to these Fair Value Procedures include but are not limited to: the security’s trading has been halted or suspended; the security has been delisted from a national exchange; the security’s primary trading market is temporarily closed at a time when under normal conditions it would be open; or the security’s primary pricing source is not able or willing to provide a price. The securities of each Portfolio may also be valued on the basis of valuations provided by a pricing service approved by, or on behalf of, the Board.

Portfolio securities listed or traded on securities exchanges, including American Depositary Receipts (“ADRs”), are valued at the closing price on the exchange or system where the security is principally traded or at the NASDAQ Official Closing Price. If there have been no sales for that day on the exchange or system, a security is valued at the mean of the highest closing bid and lowest asked prices on the exchange or system where the security is principally traded.

Fair Value Measurements: Valuation inputs used to determine the value of the Portfolios’ investments are summarized in the three broad levels listed below:

Level 1 — Unadjusted quoted prices in active markets for identical assets and liabilities that the Funds have the ability to access.

Level 2 — Observable inputs other than quoted prices included in Level 1 that are observable for the asset or liability, either directly or indirectly. These inputs may include quoted prices for the identical instrument in an inactive market, prices for similar instruments, interest rates, prepayment speeds, credit risk, yield curves, default rates and similar data.

Level 3 — Unobservable inputs for the asset or liability, to the extent relevant observable inputs are not available, representing the Funds’ own assumptions about the assumptions a market participant would use in valuing the asset or liability, and would be based on the best information available.

The inputs or methodology used to value securities are not necessarily an indication of the risk associated with investing in those securities.

Portfolio securities listed or traded on securities exchanges, including ADRs, are valued at the closing price on the exchange or system where the security is principally traded or at the NASDAQ Official Closing Price. If there have been no sales for that day on the exchange or system, a security is valued at the mean of the highest closing bid and lowest asked prices on the exchange or system where the security is principally traded. These valuations are typically categorized as Level 1 in the fair value hierarchy.

In accordance with procedures adopted by the Board, fair value pricing may be used if events materially affecting the value of foreign securities occur between the times the exchange on which they are traded closes and the time the Portfolios’ net asset values are calculated. These valuations are categorized as Level 2 in the fair value hierarchy.

The following is a summary categorization, as of March 31, 2022, of each Portfolio’s investments based on the level of inputs utilized in determining the value of such investments:


Needham Aggressive Growth Fund
Assets ⁽¹⁾	Level 1		Level 2		Level 3		Total
Common Stocks	$	119,751,343	$	-	$	-	$	119,751,343
Short-Term Investments		34,739,417		-		-		34,739,417
Total	$	154,490,760	$	-	$	-	$	154,490,760


Needham Growth Fund
Assets ⁽¹⁾	Level 1		Level 2		Level 3		Total
Common Stocks	$	165,952,105	$	-	$	-	$	165,952,105
Short-Term Investments		4,082,309		-		-		4,082,309
Total	$	170,034,414	$	-	$	-	$	170,034,414

Needham Small Cap Growth Fund
Assets ⁽¹⁾	Level 1		Level 2		Level 3		Total
Common Stocks	$	216,940,529	$	-	$	-	$	216,940,529
Warrants		-		-		22,610		22,610
Short-Term Investments		29,671,646		-		-		29,671,646
Total	$	246,612,175	$	-	$	22,610	$	246,634,785

⁽¹⁾

Please refer to the Schedule of Investments to view segregation by industry.

3. Transactions with Affiliates

NAGF owned 5% or more of the voting securities of the following company during the three months ended March 31, 2022. As a result, this company is deemed to be an affiliate of NAGF as defined by the 1940 Act. Transactions during the period in this affiliated company were as follows:

Security Name		Value at January 1, 2022				Value of Purchases				Value of Sales				Net Change in Unrealized Appreciation (Depreciation)				Net Realized Gains (Losses)				Dividend Income				Value at March 31, 2022				Share Balance March 31, 2022
GSE Systems, Inc.		$	2,332,440			$	204,620			$	-			$	582,940			$	-			$	-			$	3,120,000				1,500,000

NSCGF owned 5% or more of the voting securities of the following company during the three months ended March 31, 2022. As a result, this company is deemed to be an affiliate of NSCGF as defined by the 1940 Act. Transactions during the period in this affiliated company were as follows:

Security Name	Value at January 1, 2022		Value of Purchases		Value of Sales		Net Change in Unrealized Appreciation (Depreciation)			Net Realized Gains (Losses)		Dividend Income		Value at March 31, 2022		Share Balance March 31, 2022
Frequency Electronics, Inc.	$	5,309,610	$	279,839	$	-	$	(630,449	)	$	-	$	-	$	4,959,000		570,000
Intevac, Inc.		8,067,288		49,474		-		1,092,995			-				9,209,757		1,721,450
Total	$	13,376,898	$	329,313	$	-	$	462,546		$	-	$	-	$	14,168,757		2,291,450