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CORRESP Filing

Aspire Biopharma Holdings, Inc.
Date: April 13, 2026 · CIK: 0001847345 · Accession: 0001493152-26-016330

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File numbers found in text: 333-293515

Date

April 13, 2026

Author

Chief

Form

CORRESP

Company

Aspire Biopharma Holdings, Inc.

Letter

Aspire Biopharma Holdings, Inc.

Fashion Drive, Suite 232

Estro, FL 33928

Tel: (908) 987-3002

April 13, 2026

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

F. Street, N.E.

Washington, D.C. 20549

Attention: Mr. Tim Buchmiller

Re: Aspire Biopharma Holdings, Inc.

Registration Statement on Form S-1

File No. 333-293515

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 5:00 p.m., Eastern Time on Tuesday, April 14, 2026, or as soon thereafter as practicable.

Please contact Arthur S. Marcus, Esq. of Sichenzia Ross Ference Carmel LLP at (516) 459-9161, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

Very
truly yours,
Aspire
Biopharma Holdings, Inc.

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CORRESP
1
filename1.htm

Aspire
Biopharma Holdings, Inc.

23150
Fashion Drive, Suite 232

Estro,
FL 33928

Tel:
(908) 987-3002

April
13, 2026

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Life Sciences

100
F. Street, N.E.

Washington,
D.C. 20549

Attention:
Mr. Tim Buchmiller

    Re:
                                            Aspire Biopharma Holdings, Inc.

    Registration
    Statement on Form S-1

    File
    No. 333-293515

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for
the Registration Statement referred to above be accelerated so that it will be declared effective at 5:00 p.m., Eastern Time on Tuesday,
April 14, 2026, or as soon thereafter as practicable.

Please
contact Arthur S. Marcus, Esq. of Sichenzia Ross Ference Carmel LLP at (516) 459-9161, as soon as the Registration Statement has been
declared effective, or if you have any other questions or concerns regarding this matter.

    Very
    truly yours,

    Aspire
    Biopharma Holdings, Inc.

    By:
    /s/
    Ernest Scheidemann

    Ernest
    Scheidemann

    Chief
    Financial Officer