Correspondence 0001493152-25-027208 from TruGolf Holdings, Inc. (TRUG)

TruGolf Holdings, Inc.
Date: Dec. 11, 2025 · CIK: 0001857086 · Accession: 0001493152-25-027208

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File numbers found in text: 333-291608

Date

Dec. 11, 2025

Author

Chief

Form

CORRESP

Company

TruGolf Holdings, Inc.

Letter

TruGolf Holdings, Inc.

North 1400 West

Centerville, Utah 84014

December 11, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

Washington, DC 20549

Re:

TruGolf Holdings, Inc.

Registration Statement on Form S-3

File No. 333-291608

Ladies and Gentlemen:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, TruGolf Holdings, Inc. (the "Company"), hereby respectfully requests that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 4:30 P.M. (Eastern Time) on December 15, 2025, or as soon thereafter as possible on such date.

Very truly yours,
TruGolf Holdings, Inc.

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CORRESP
 1
 filename1.htm

 TruGolf
Holdings, Inc.

 60
North 1400 West

 Centerville,
Utah 84014

 December
11, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporate Finance

 Washington,
DC 20549

 Re:

 TruGolf
 Holdings, Inc.

 Registration
 Statement on Form S-3

 File
 No. 333-291608

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 of the Securities Act of 1933, as amended, TruGolf Holdings, Inc. (the "Company"), hereby respectfully requests
that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 4:30
P.M. (Eastern Time) on December 15, 2025, or as soon thereafter as possible on such date.

 Very truly yours,

 TruGolf Holdings, Inc.

 /s/
 Christopher (Chris) Jones

 Name:
 Christopher
 (Chris) Jones

 Title:
 Chief
 Executive Officer

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