SecProbe.io

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 December 1, 2025

Michael Rowe
Chief Executive Officer
Hyperion DeFi, Inc.
23461 S. Pointe Drive, Suite 390
Laguna Hills, CA 92653

 Re: Hyperion DeFi, Inc.
 Amendment No. 1 to Registration Statement on Form S-3
 Filed September 29, 2025
 File No. 333-288776
Dear Michael Rowe:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our July 31,
2025 letter.

Amendment No. 1 to Registration Statement on Form S-3
Prospectus Summary
HYPE Treasury, page 5

1. Please revise to describe the lifecycle of a HYPE token transaction.
2. Please disclose the material terms of your custody arrangements with
Anchorage
 including whether your HYPE tokens will be held in hot or cold storage.
Clarify
 whether your custodian has insurance covering the crypto assets it
holds, describe the
 type and amount of insurance coverage, and state whether this coverage
is specific to
 you or is shared among Anchorage's customers.
 December 1, 2025
Page 2
3. Regarding your staking program, please address the following:
 Disclose the percentage of validator commissions you pay to each of
Kinetiq and
 Pier Two pursuant to the Joint Validator Operators Agreement as
discussed in
 your 10-Q for the period ended September 30, 2025.
 Disclose the policies and procedures you have for your staking
plans, including,
 for example, what percentage of your HYPE tokens you intend to stake.
 Discuss any liquidity risks (if material) with your staking plans,
including the
 liquidity risks related to the HYPE token unbonding period.
4. We note disclosure in your Form 10-Q for the period ended September 30,
2025 that
 you provided Felix with the HYPE required to launch a perpetual futures
market and
 will earn a share of the fees earned from trading activity. Please
disclose whether this
 perpetual futures market will exist in the United States or will be
subject to CFTC
 regulation.
Risk Factors, page 9

5. Please include a separate risk factor addressing the 238 million HYPE
tokens being
 unlocked over the next two years and the resulting negative impact this
could have on
 the price of HYPE tokens.

 Please contact Lauren Hamill at 303-844-1008 or Laura Crotty at
202-551-7614 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Keunjung Cho
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