CORRESP Filing
Bakkt, Inc.
Date: July 21, 2025 · CIK: 0001820302 · Accession: 0001193125-25-161748
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File numbers found in text: 333-288362
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CORRESP 1 filename1.htm CORRESP July 21, 2025 Via EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Crypto Assets 100 F Street, N.E. Washington, D.C. 20549 Attention: Sonia Benarowski Lulu Cheng Re: Bakkt Holdings, Inc. Registration Statement on Form S-3 (File No. 333-288362) Acceleration Request Requested Date: Wednesday, July 23, 2025 Requested Time: 4:30 P.M. Eastern Time Ladies and Gentleman: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Bakkt Holdings, Inc. (the “Company”) hereby requests that the above-referenced Registration Statement (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above or as soon as practicable thereafter, or at such other time as the Company or its outside counsel, Sullivan & Cromwell LLP, requests by telephone that such Registration Statement be declared effective. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Sullivan & Cromwell LLP, by calling Mario Schollmeyer at (212) 558-3287. Sincerely, BAKKT HOLDINGS, INC. /s/ Akshay Naheta Name: Akshay Naheta Title: Co-Chief Executive Officer cc: Marc D’Annunzio, Bakkt Holdings, Inc. Paul Simmons, Bakkt Holdings, Inc. Jared Fishman, Sullivan & Cromwell LLP Matt Goodman, Sullivan & Cromwell LLP Mario Schollmeyer, Sullivan & Cromwell LLP