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CORRESP
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 CORRESP

 VIA EDGAR CORRESPONDENCE
 Office of International Corporate Finance Attn. Samuel Kluck;
Michael Coco Securities and Exchange Commission Division of
Corporation Finance 100 F Street, NE Washington, D.C. 20549

 Re:
 United Mexican States
 Draft Registration Statement under Schedule B
 Submitted July 11, 2025
 CIK No. 0000101368
 Form 18-K for fiscal year ended December 31, 2024
 Filed June 20, 2025, amended July 2, 2025 and July 22, 2025
 Dear Mr. Kluck and Mr. Coco: This
letter responds to comments of the staff (the “ Staff ”) of the Securities and Exchange Commission (the “ Commission ”) set forth in the letter dated August 6, 2025 (the “ August 6
letter ”), regarding the above-referenced Registration Statement under Schedule B (the “ Registration Statement ”) and the annual report on Form 18-K for the fiscal year
ended December 31, 2024 (the “ 18-K for 2024 ”) of the United Mexican States (“ UMS ” or “ Mexico ”), as amended on Form 18-K/A by Amendment No. 1 to the 18-K for 2024 (“ Amendment No. 1 ”) and Amendment No. 2 (“ Amendment
No. 2 ”) to the 18-K for 2024, filed on July 2, 2025 and July 22, 2025, respectively. The 18-K for 2024 together with Amendment
No. 1 and Amendment No. 2 shall be referred herein as the “ 18-K .”
 For your convenience, we have reproduced below in bold the Staff’s comments numbered to correspond with the numbers in your
August 6 letter, and provided responses immediately below the comments. With this letter, and bearing the same date, UMS is filing Amendment No. 3 to the 18-K for 2024 on Form 18-K/A (“ Amendment No. 3 ”). Capitalized terms used and not defined herein have the meanings assigned in the 18-K.
 Form 18-K for Fiscal Year Ended December 31, 2024, Exhibit 99.D
 Principal Sectors of the Economy PEMEX, page
 D-78

 1.
 We note your disclosure on page D-79 that, “In 2024, the
Government contributed approximately Ps. 156.5 billion to PEMEX ... The PEMEX 2025 budget contemplates a financial balance of Ps. 248.7 billion, including a capital contribution from the Mexican Government of Ps. 136.2 billion for
debt amortization.” Please disclose the total amount of capital contribution budgeted from the Mexican Government to PEMEX in 2025.
 Mexico acknowledges the Staff’s comment and advises the Staff that in response to the Staff’s comment Mexico has updated its 18-K by filing Amendment No. 3 to include disclosure on the total amount of capital contribution budgeted from the Mexican Government to PEMEX in 2025.

 2.
 We note your disclosure that, “Effective as of March 19, 2025 ... PEMEX was transformed from a
productive state-owned company into a state-owned public company. For more information, See ‘Recent Developments ... Electric Power.’” Please provide more information on the differences between the two legal structures and the
reasons for the change in ownership structure. Please include, for example, information on any changes in being subject to bankruptcy protection under Mexican law.
 Mexico acknowledges the Staff’s comment and advises the Staff that in response to the Staff’s comment Mexico has updated its 18-K by filing Amendment No. 3 to include disclosure on the changes in PEMEX’s corporate mission and activities resulting from the transformation from a productive state-owned company into a state-owned
public company and the reasons for the change in PEMEX’s ownership structure. Additionally, Mexico advises the staff that
(i) under the Federal Public Administration Law ( Ley Orgánica de la Administración Pública Federal ). PEMEX is classified as a public sector entity ( entidad paraestatal ) and (ii) pursuant to the fourth
transitory provision of the Ley de Concursos Mercantiles (Commercial Bankruptcy Law) public sector entities that are not organized in accordance with private commercial law, such as PEMEX, are not subject to bankruptcy proceedings. Therefore,
PEMEX is not subject to the Commercial Bankruptcy Law nor any bankruptcy protection under Mexican law. However, PEMEX’s status as a legal entity not subject to bankruptcy proceedings precedes, and was not changed by PEMEX’s
transformation from a state-owned company into a state-owned public company.

 3.
 We note your disclosure on page D-79 that “the Government has
further supported the measure outlined in the Program ... through various tax and credit deferrals.” The disclosure also indicates that, since 2019, there has been a reduction in Profit-Sharing Duty with reduced percentages. In addition, it
states that, “The new tax regime ... is expected to generate savings of Ps. 50.0 billion ...” Either in this section or the Revenues section on page D-134, and to the extent material, please
discuss and quantify the impact of the tax and credit deferrals upon Mexico’s budgetary revenues within a reasonable time period.
 Mexico acknowledges the Staff’s comment and advises the Staff that in response to the Staff’s comment Mexico has updated its 18-K by filing Amendment No. 3 to include disclosure on the impact of the tax and credit deferrals from the Program to Strengthen Petróleos Mexicanos on Mexico’s budgetary results. In
particular, Mexico advises the Staff that the impact of the tax and credit and deferrals upon Mexico’s budgetary revenues is fiscally neutral with respect to the Public Sector’s fiscal balance, as it entails a redistribution of resources
between PEMEX and the Federal Government. Performance, page D-80

 4.
 We note your disclosure that, “Recent Information regarding the financial condition of PEMEX can be
found in the annual report furnished by PEMEX to the SEC on Form 20-F on April 29, 2025 ...” We also note the highlighted disclosures under the subheading “Performance” on page D-80. Given the significance of PEMEX’s operations and financial condition on Mexico’s budget, revenues and expenses, please include a discussion and analysis of PEMEX’s financial condition and
results of operations in Mexico’s Form 18-K. This discussion should include an analysis of the PEMEX’s ability to generate and obtain adequate amounts of cash to meet its requirements and, to the
extent applicable, please identify any known trends that are reasonably likely to result in PEMEX’s liquidity increasing or decreasing in a material way.
 Mexico acknowledges the Staff’s comment and advises the Staff that in response to the Staff’s comment Mexico has updated its 18-K by filing Amendment No. 3 to include disclosure on PEMEX’s financial condition and results of operations.
 2

 Revenues and Expenditures
 Budgetary Revenues, page D-134

 5.
 In the narrative to Table No. 63 – Public Sector Budgetary Revenues, please describe the amount
of tax revenue received from PEMEX. Mexico acknowledges the Staff’s comment and advises the Staff that in
response to the Staff’s comment Mexico has updated its 18-K by filing Amendment No. 3, which includes a narrative description of PEMEX’s contribution Public Sector budgetary revenues (which are also set forth in the line
corresponding to PEMEX in Table No. 63 – Public Sector Budgetary Revenues), as well as the amount of such contribution corresponding to tax contributions.
 Government Agencies and Enterprises Table
66 - Principal Government Parastatal Agencies, State-Owned Public Companies and Enterprises at December 32, 2024, page D-143

 6.
 We note the column for Total Assets. Please include a column for total liabilities of the listed entities.
 Mexico acknowledges the Staff’s comment and advises the Staff that in response to the Staff’s comment
Mexico has updated its 18-K by filing Amendment No. 3, which amends and restates Table 66 – Principal Government Parastatal Agencies, State-Owned Public Companies and Enterprises of the 18-K.

 7.
 We note the column Contribution or Expense to Primary Balance and the footnote to that column,
“Surplus after Government transfers, less interest payments.” Please describe in the narrative to the table how the U.S. $8,155.8 million was calculated. For example, please reconcile with the public sector budgetary expenditures
for PEMEX in Table No. 65 and the public sector budgetary revenues in Table No. 63 or advise. Mexico
acknowledges the Staff’s comment and advises the Staff that in response to the Staff’s comment Mexico has updated its 18-K by filing Amendment No. 3, which amends and restates Table 66 –
Principal Government Parastatal Agencies, State-Owned Public Companies and Enterprises of the 18-K.
 Additionally, Mexico advises the Staff that PEMEX’s Contribution or Expense to Primary Balance, which is calculated as total income,
less expense, plus interest expense, can be calculated from the revenue and expense figures corresponding to PEMEX presented in Table No. 63 and Table No. 65, respectively, by translating them from Mexican pesos to U.S. dollars at the rate
of Ps. 20.7862 per U.S.$1.00, as indicated in footnote (4) to Table No. 66 – Principal Government Parastatal Agencies, State Owned Public Companies and Enterprises. Mexico advises the Staff that it has included a narrative
description of the calculation of PEMEX’s Contribution or Expense to Primary Balance to further clarify this point.
 3

 Public Debt, page D-144

 8.
 Please confirm that PEMEX’s external public debt is not included in the tables in this section and, if
not, please advise why it is omitted. We note that Table No. 68 – Gross and Net Internal Debt of the Public Sector includes gross debt of PEMEX. We further note the disclosure in Table No. 65 – Public Sector Budgetary
Expenditures includes a separate line item for interest for PEMEX as a budgetary expenditure. Mexico acknowledges
the Staff’s comment and advises the Staff that Mexico reports its debt figures at three different levels: debt of the Government, debt of the Public Sector and the Balance of Public Sector Financial Requirements. Government debt includes all
Federal Government financial obligations incurred by the Legislative and Judicial branches and all agencies of the Federal Executive Branch (including their decentralized bodies), as well as obligations incurred by autonomous bodies that were part
of the Federal Public Administration at the time of the incurrence. Public Sector debt consists of Government debt, plus the obligations of entities under direct budgetary control (those for which revenues and expenditures are included in
Mexico’s annual budget), state-owned public enterprises and their subsidiaries, and development banks. Public Sector Financial Requirements includes Public Sector debt, plus certain financial obligations that are not considered “Public
Sector debt” as a result of the relevant Mexican regulations and budgetary practices, including the net financial obligations of the Instituto para la Protección al Ahorro Bancario (Institute for the Protection of Bank Savings)
and the debtor support program, the obligations of the Proyectos de Inversión de Infraestructura Productiva con Registro Diferido en el Gasto Público (Productive Infrastructure Investment Projects with Deferred Registration
in Public Spending), the obligations arising from the Fondo Nacional de Infraestructura (National Infrastructure Fund) (FONADIN), and the assets of development institutions.
 As a result, PEMEX’s public debt is included in all tables of the 18-K for 2024 that present
Public Sector debt figures (Table No. 68 – Gross and Net Internal Debt of the Public Sector, Table No. 71 – Summary of External Public Sector Debt by Type, Table No. 72 – Summary of External Public Sector Debt by
Currency and Table No. 73 – Net External Debt of the Public Sector), as well as in Table No. 67 – Historical Balance of Public Sector Borrowing Requirements. However, PEMEX’s debt is not included in the tables of the 18-K for 2024 that present Government debt figures. Form 18-K/A filed on
July 22, 2025 Exhibit 99-1, page E-1

 9.
 To the extent material, please disclose the amount of contributions paid by the Mexican Government to PEMEX
in the first quarter or longer period in 2025 and explain the reasons for the contribution. If this amount differs from the amount budgeted by the Mexican Government to contribute to PEMEX in 2025, please explain.
 Mexico acknowledges the Staff’s comment and advises the Staff that in response to the Staff’s comment Mexico has updated its 18-K by filing Amendment No. 3 to include disclosure on the contributions paid by the Mexican Government to PEMEX in the first half of 2025.

 10.
 Please revise or advise to describe the Luxembourg special purpose vehicle (SPV) in more detail. For
example, please describe the type of organization and whether the Mexican Government, or through the Ministry of Finance and Public Credit, will hold all of the equity ownership of the SPV. Please describe if the Mexican Government will also manage
the SPV and, if not, please explain. In addition, if applicable, please describe whether the SPV will have any other purpose other than to issue precapitalized securities (P-Caps) and purchase eligible assets
such as U.S. Treasuries and related securities and Mexico’s notes 2030 upon the occurrence of certain events.
 Mexico acknowledges the Staff’s comment and advises the Staff that in response to the Staff’s comment Mexico has updated its 18-K by filing Amendment No. 3 to include disclosure describing the Luxembourg special purpose vehicle (SPV) in more detail.
 4

 The SPV, Eagle Funding LuxCo S.à r.l. (“ Eagle Funding ”) a private
limited liability company ( société à responsabilité limitée ) (“ Eagle Funding ”) organized and existing under the laws of the Grand Duchy of Luxembourg (“ Luxembourg ”), is
acting in respect of its compartment “EFL Compartment I” (“ EFL I ”) in connection with the P-Caps offering and its resulting obligations. While it is customary for precapitalized
securities issued by domestic sponsors to be issued through a Delaware trust, the P-Caps are being issued through a Luxembourg vehicle due to Mexico’s status as a foreign sovereign nation. The corporate
objects of Eagle Funding are, among others, to enter into, perform and serve as a vehicle for, any securitization transactions as permitted under the Luxembourg Securitization Act 2004 and to enter into any agreement and perform any action necessary
or deemed helpful for the purpose of carrying out transactions permitted by the Luxembourg Securitization Act 2004, so far as they relate to securitization transaction. Additionally, Eagle Funding has formed EFL I for the exclusive purposes of:

 •

 entering into the P-Caps Indenture to facilitate the issuance of the P-Caps;

 •

 issuing the P-Caps and entering into a purchase agreement for that
purpose;

 •

 investing the net proceeds from the issuance and sale of the P-Caps in
Eligible Assets;

 •

 entering into the Facility Agreement, under which it could have the obligation to purchase Mexico’s Notes
due 2030 (the “ Notes ”);

 •

 entering into a pledge and control agreement, for the benefit of Mexico, to secure the obligations of EFL I to
Mexico and to perfect such security interest;

 •

 entering into an uncollateralized global master securities lending agreement (the “ GMSLA ”)
with PEMEX;

 •

 entering into an expense reimbursement agreement with Mexico in connection with EFL I’s establishment costs
and expenses inherent to the operation or liquidation and termination of Eagle Funding or EFL;

 •

 delivering Eligible Assets to, and accepting the return of Eligible Assets from, PEMEX;

 •

 accepting any substitute payments in connection with the Eligible Assets;

 •

 redeeming the P-Caps or a portion thereof in accordance with the P-Caps Indenture;

 •

 distributing cash payments that EFL I receives, after paying any expenses and other amounts payable by EFL I, to
the holders of the P-Caps;

 •

 holding the Eligible Assets and the other assets of EFL I, receiving amounts in immediately available funds from
Mexico or PEMEX with respect to any (a) defaulted interest payments under