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CORRESP Filing

SUI Group Holdings Ltd.
Date: Sept. 29, 2025 · CIK: 0001425355 · Accession: 0001213900-25-093046

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File numbers found in text: 333-289201

Date
September 29, 2025
Author
/s/ Douglas Polinsky
Form
CORRESP
Company
SUI Group Holdings Ltd.

Letter

Sui Group Holdings Limited

1907 Wayzata Boulevard, Suite 205

Wayzata, MN 55391

September 29, 2025

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Crypto Assets

100 F Street, N.E.

Washington, D.C. 20549

Re: Sui Group Holdings Limited

Registration Statement on Form S-1

File No. 333-289201

To whom it may concern:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Sui Group Holdings Limited (the " Company ") hereby respectfully requests that the effective date of the Company's Registration Statement on Form S-1 (File No. 333-289201) be accelerated by the Securities and Exchange Commission to 4:00 p.m., Eastern Time, on September 30, 2025 or as soon as practicable thereafter.

Sincerely,
/s/ Douglas Polinsky

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CORRESP
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 filename1.htm

 Sui Group Holdings Limited

 1907 Wayzata Boulevard, Suite 205

 Wayzata, MN 55391

 September 29, 2025

 Via EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Crypto Assets

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Sui Group Holdings Limited

 Registration Statement on Form S-1

 File No. 333-289201

 To whom it may concern:

 Pursuant to Rule 461 under the Securities Act of
1933, as amended, Sui Group Holdings Limited (the " Company ") hereby respectfully requests that the effective
date of the Company's Registration Statement on Form S-1 (File No. 333-289201) be accelerated by the Securities and Exchange Commission
to 4:00 p.m., Eastern Time, on September 30, 2025 or as soon as practicable thereafter.

 Sincerely,

 /s/ Douglas Polinsky

 Name:
 Douglas Polinsky

 Title:
 Chief Executive Officer

 cc:
 Alexandria Kane, Loeb & Loeb LLP