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CORRESP
 1
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 Perkins
 Coie LLP
 1301 Second
 Avenue
 Suite
 4200
 Seattle,
 WA 98101
 T.
 +1.206.359.8000
 F.
 +1.206.359.9000
 perkinscoie.com

 October
14, 2025

 VIA
EDGAR AND ELECTRONIC MAIL

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Crypto Assets

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention: David
 Gessert

 David
 Lin

 Re: DeFi
 Development Corp.

 Registration
 Statement on Form S-1

 Filed
 September 9, 2025

 File
 No. 333-290133

 Ladies
and Gentlemen:

 On
behalf of DeFi Development Corp., an Delaware corporation (the “ Company ”), we are providing this letter in response
to comments received from the staff (the “ Staff ”) of the Securities and Exchange Commission (the “ Commission ”)
by letter dated September 23, 2025 (the “ Comment Letter ”) with respect to the Company’s Registration Statement
on Form S-1, as filed on September 9, 2025 (“ Registration Statement ”).

 This
letter is being submitted together with the Amendment No. 1 to the Company’s Registration Statement on Form S-1 (“ Amendment
No. 1 ”), which reflects certain revisions to the Registration Statement in response to the Comment Letter, as well as certain
other changes. For your convenience, we are supplementally providing you with a copy of Amendment No. 1, which has been marked to show
changes from the Registration Statement, as well as a copy of this letter.

 October
14, 2025

 Page
2

 For
ease of review, we have set forth below each of the numbered comments of your letter in bold type, followed by the Company’s responses
thereto. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in Amendment No. 1 and all references
to page numbers in such responses are to page numbers in Amendment No. 1.

 Registration
Statement on Form S-1

 Prospectus
Summary

 Our
Company

 Digital
Asset Treasury Strategy, page 1

 1. You
 disclose that your new treasury policy updated your treasury management to "include
 digital assets, starting with SOL" and that "[m]anagement intends to focus on accumulating
 digital assets, focusing on SOL, and holding it long-term." Please expand to discuss
 your intentions to acquire other crypto assets, if any. To the extent you intend to acquire
 a material amount of other crypto assets, please add a section that addresses the characteristics
 of such crypto assets and the network on which they exist as well as any material risks related
 to your investment therein. If management does not currently have any such plans, please
 so state.

 Response:
 The Company respectfully acknowledges the Staff's comment and
has revised the disclosure on pages 1 and 13 of Amendment No. 1.

 Digital
Asset Treasury Strategy Revenue, page 2

 2. We
 note your disclosure that "[w]e derive revenue from our digital asset treasury strategy
 through delegating a portion of our digital asset holdings with third-party validators…
 Additionally, we earn validator revenue from participating in the Solana network through
 creating and validating transactions using our owned validators." Please revise to address
 the following points:

 ● Quantify
 the portions of your crypto asset holdings that are allocated to your owned validator nodes
 and to third-party nodes, respectively.

 ● Expand
 your disclosure to quantify the costs of operating your own validator nodes and address how
 and whether such operations have a material impact on your profitability.

 ● Quantify
 the amount of SOL that is staked to your owned validator nodes by third parties.

 Response:
 The Company respectfully acknowledges the Staff's comment and
has revised the disclosure on pages 2, 13 and 14 of Amendment No. 1.

 3. We
 note your disclosure that "[i]n exchange for staking our digital assets, we receive
 approximately 10% of the validators' total earned rewards in the form of SOL, net of commission
 fees." Please revise to discuss how such amount that you receive is determined. Also,
 please revise to explain how the validators' total earned rewards in the form of SOL is determined
 and calculated and quantify the approximate amount of the validators' commission fees you
 reference.

 Response:
 The Company respectfully acknowledges the Staff's comment and
has revised the disclosure on pages 2 and 13 of Amendment No. 1 to clarify how rewards from validators are determined and the approximate
commission fees that the Company pays.

 October
14, 2025

 Page
3

 Business

 Description
of Our Segments

 Digital
Asset Treasury Strategy, page 13

 4. Please
 expand your disclosure to describe your plan of operation for the next 12 months by disclosing:

 ● The
 amount and proportions of SOL and/or other crypto assets you have purchased or intend to
 purchase;

 ● The
 amount of capital you intend to raise through equity issuances and debt financing for such
 acquisitions. In this regard, we note your disclosure on page 14 that you use proceeds primarily
 from financing activities that consist of equity issuances and debt financing to acquire
 SOL; and

 ● An
 estimated timeline for building your digital asset treasury over this time period.

 Response:
 The Company respectfully acknowledges the Staff's comment and
has revised the disclosure on page 13 of Amendment No. 1.

 5. We
 note your disclosure that "[w]e delegate ('stake') a portion of our digital assets,
 primarily locked SOL, with third party validators… In some cases, we jointly own and
 operate validators alongside ecosystem partners to further align our treasury strategy with
 the broader Solana network." Please revise to provide a materially complete description
 of your staking program. In this regard, please address each of the following points with
 respect to your (i) delegated staking activities with third party providers and (ii) staking
 activities conducted through your owned validators that you operate, as applicable:

 ● State
 whether you have any target percentage of your SOL holdings that you stake.

 ● Describe
 in greater detail the mechanics of the staking process.

 ● Disclose
 the material terms of your agreements with your staking providers, and summarize the responsibility
 and duties of the staking providers thereunder.

 ● Describe
 your plans with respect to the use of proceeds from staking rewards.

 ● Disclose
 with specificity the bonding and unbonding periods associated with staking SOL, discuss how
 they affect liquidity and disclose the material terms of any policies and procedures you
 have in place to manage liquidity in this regard.

 Response:
 The Company respectfully acknowledges the Staff's comment and
has revised the disclosure on pages 13 and 14 of Amendment No. 1.

 6. Please
 expand your disclosure to describe the policies and procedures you have in place or intend
 to adopt that govern when you exchange cash for crypto assets and when you monetize your
 crypto assets. Disclose whether you have policies or will establish policies governing the
 percentage of your treasury holdings that will be SOL. In addition, please disclose whether
 you intend to hedge your exposure to SOL and, if so, please describe your hedging strategy.
 Further, provide related risk factor disclosure, if material and to the extent applicable.

 Response:
 The Company respectfully acknowledges the Staff's comment and
has revised the disclosure on pages 1, 13 and 14 of Amendment No. 1 to clarify that the Company's current policy does not set a
specific target with respect to the amount of digital assets held and to provide additional disclosure on the Company's approach
to accumulate and hold digital assets, focusing on SOL, for the long-term. The Company respectfully advises the Staff that it does not
have a policy regarding monetization of its crypto assets given the current focus on accumulating and holding such assets. The Company
has updated the disclosure on pages 2 and 14 of Amendment No. 1 to clarify that the Company does not currently hedge its exposure to SOL
price fluctuations, but may do so in the future. In light of the current policies and procedures, the Company believes that the material
and applicable risk factors are disclosed.

 October
14, 2025

 Page
4

 7. On
 page 14, you disclose that you "rely on various counterparties which includes, among
 others, Kraken, BitGo and Galaxy, to safeguard [your] digital asset holdings and execute
 trading on [your] behalf." Please supplementally confirm whether you have disclosed
 the identities of the material counterparties in this regard. With respect to each material
 counterparty, please describe the material terms of your agreement(s), including, without
 limitation, the term and termination provisions, and file the same as exhibits to your registration
 statement, if required by Item 601 of Regulation S-K. For any material counterparty that
 provides custodial services for your crypto assets, please also disclose:

 ● The
 proportion of private keys that are held in hot, warm or cold storage;

 ● Whether
 your assets are held in segregated accounts;

 ● The
 identity of entities that have access to the custodied assets;

 ● Whether
 any entity is responsible for verifying the existence of your crypto assets;

 ● Whether
 and to what extent the third-party custodian carries insurance for any losses of the crypto
 assets it custodies for you; and

 ● Where
 the custodian is chartered and how it is regulated.

 Response:
 In response to the Staff's comment, the Company respectfully advises
the Staff that the Company has updated its disclosure on page 14 of Amendment No. 1 to include additional information about the applicable
security and regulations applicable to the counterparties and insurance details, where available. Additionally, the Company respectfully
advises the Staff that it has reviewed its arrangements and relationship with each of the counterparties, and based on its review, the
Company believes that it is not required to file any such agreement as an exhibit pursuant to Item 601 of Regulation S-K. The agreements
or arrangements with Kraken, BitGo and Galaxy are each the type of arrangement that typically accompanies the kind of business conducted
by the Company in the ordinary course of its business, and they are not contracts on which the Company's business is substantially
dependent. While these counterparties are leading providers of trading or custody arrangements for digital assets, the Company respectfully
submits that other providers provide comparable offerings and the Company believes that alternative providers could provide services that
are substantially similar to the services the Company receives from its existing counterparties. In addition, the Company believes that
it could transition to alternative providers on commercially reasonable terms, if management were to determine that doing so would be
in the best interest of the Company. For the foregoing reasons, the Company does not believe that its business is substantially dependent
on its arrangements with Kraken, BitGo or Galaxy, and therefore does not believe it is required to file the agreements as an exhibits
pursuant to Item 601 of Regulation S-K.

 October
 14, 2025

 Page
5

 8. We
 note your disclosure on page 14 that, "Kraken accounts for approximately 95% of our
 trading volume and approximately 30% of our digital assets holding are at both BitGo and
 Galaxy." Please revise to clarify the approximate percentage of your crypto asset holdings
 that are held at each material third party custodian, respectively.

 Response:
 The Company respectfully acknowledges the Staff's comment and
has revised the disclosure on page 14 of Amendment No. 1.

 Solana
Network, page 15

 9. Please
 revise this section to provide greater detail describing SOL and the Solana blockchain, including:

 ● The
 market capitalization and average daily trading volume of SOL;

 ● The
 past and current supply of SOL;

 ● The
 launch date of SOL and the Solana blockchain; and

 ● The
 governance of the Solana blockchain.

 Response:
 The Company respectfully acknowledges the Staff's comment and
has revised the disclosure on page 16 of Amendment No. 1.

 10. We
 note your disclosure that the Solana network enables users to instantly send money globally,
 trade digital assets, utilize smart contracts, and buy or sell fungible and non-fungible
 tokens. Please revise to quantify or otherwise describe the nature and level of activity
 for each of these identified use cases, and quantify the number of active developers on the
 Solana network as of the most recent practicable date, to the extent known.

 Response:
 The Company respectfully acknowledges the Staff's comment and
has revised the disclosure on page 16 of Amendment No. 1.

 ****************************

 October
14, 2025

 Page
6

 We hope that the Company's responses above adequately address the Staff's comments. If the Staff has any questions or requires
any additional information, please do not hesitate to contact me at (206) 359-3295.

 Very truly yours,

 /s/
 Allison C. Handy

 Allison C. Handy

 Perkins Coie LLP

 cc:
 Joseph Onorati, DeFi Development Corp.