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CORRESP Filing

DeFi Development Corp. (DFDV, DFDVW, DFUKF) (CIK 0001805526)
Date: April 23, 2026 · CIK: 0001805526 · Accession: 0001805526-26-000022

Offering / Registration Process Regulatory Compliance Business Model Clarity

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File numbers found in text: 333-295142

Date
April 23, 2026
Author
/s/ Joseph Onorati
Form
CORRESP
Company
DeFi Development Corp. (DFDV, DFDVW, DFUKF) (CIK 0001805526)

Letter

Document

DeFi Development Corp.

6401 Congress Avenue, Suite 250

Boca Raton, FL 33487

April 23, 2026

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: DeFi Development Corp.

Registration Statement on Form S-3

Filed April 17, 2026

File No. 333-295142

To whom it may concern:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, DeFi Development Corp. (the “Company”) hereby respectfully requests that the effective date of the Company’s Registration Statement on Form S-3 (File No. 333-295142) (the “Registration Statement”) be accelerated by the U.S. Securities and Exchange Commission so that the Registration Statement will become effective at 4:30 p.m., Eastern Time, on April 27, 2026, or as soon as practicable thereafter.

The Company requests that it be notified of such effectiveness by a telephone call to Allison Handy of Perkins Coie LLP at (206) 359-3295 and that such effectiveness also be confirmed in writing.

Sincerely,
/s/ Joseph Onorati

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CORRESP
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Document

DeFi Development Corp.

6401 Congress Avenue, Suite 250

Boca Raton, FL 33487

April 23, 2026

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: DeFi Development Corp.

 Registration Statement on Form S-3

 Filed April 17, 2026

 File No. 333-295142

To whom it may concern:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, DeFi Development Corp. (the “Company”) hereby respectfully requests that the effective date of the Company’s Registration Statement on Form S-3 (File No. 333-295142) (the “Registration Statement”) be accelerated by the U.S. Securities and Exchange Commission so that the Registration Statement will become effective at 4:30 p.m., Eastern Time, on April 27, 2026, or as soon as practicable thereafter.

The Company requests that it be notified of such effectiveness by a telephone call to Allison Handy of Perkins Coie LLP at (206) 359-3295 and that such effectiveness also be confirmed in writing.

 Sincerely,

 /s/ Joseph Onorati

 Name: Joseph Onorati

 Title: Chief Executive Officer

cc: Allison Handy, Perkins Coie LLP

Christopher Wassman, Perkins Coie LLP

187018318.1