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CORRESP Filing

Galaxy Digital Inc.
Date: May 27, 2025 · CIK: 0001859392 · Accession: 0001628280-25-028000

Offering / Registration Process Regulatory Compliance Business Model Clarity

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File numbers found in text: 333-287604

Date
May 27, 2025
Author
Danielle Freeman
Form
CORRESP
Company
Galaxy Digital Inc.

Letter

Document May 27, 2025 BY EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Lulu Cheng, Sandra Hunter Berkheimer Re: Galaxy Digital Inc. Registration Statement Filed on Form S-1, as amended File No. 333-287604 Dear Ms. Cheng and Ms. Berkheimer: In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of Galaxy Digital Inc. (the “Company”) for acceleration of the effective date of the above-referenced Registration Statement so that it becomes effective at 4:00 p.m., Eastern Time on May 29, 2025 or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Davis Polk & Wardwell LLP, request by telephone that such Registration Statement be declared effective. Pursuant to Rule 460 under the Act, please be advised that we will take reasonable steps to secure adequate distribution of the preliminary prospectus, to the underwriters, dealers, institutions and others, prior to the requested effective time of the Registration Statement. We, the undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [Signature Page Follows] Very truly yours, Goldman Sachs & Co. LLC Jefferies LLC Morgan Stanley & Co. LLC As Representatives of the several Underwriters GOLDMAN SACHS & CO. LLC /s/ Danielle Freeman Name: Danielle Freeman Title: Managing Director JEFFERIES LLC /s/ Michael Bauer Name: Michael Bauer Title: Managing Director MORGAN STANLEY & CO. LLC /s/ Daniel Croitoru Name: Daniel Croitoru Title: Vice President [Signature Page to Underwriters’ Acceleration Request]

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CORRESP
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 Document May 27, 2025 BY EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Lulu Cheng, Sandra Hunter Berkheimer Re: Galaxy Digital Inc. Registration Statement Filed on Form S-1, as amended File No. 333-287604 Dear Ms. Cheng and Ms. Berkheimer: In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of Galaxy Digital Inc. (the “Company”) for acceleration of the effective date of the above-referenced Registration Statement so that it becomes effective at 4:00 p.m., Eastern Time on May 29, 2025 or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Davis Polk & Wardwell LLP, request by telephone that such Registration Statement be declared effective. Pursuant to Rule 460 under the Act, please be advised that we will take reasonable steps to secure adequate distribution of the preliminary prospectus, to the underwriters, dealers, institutions and others, prior to the requested effective time of the Registration Statement. We, the undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [Signature Page Follows] Very truly yours, Goldman Sachs & Co. LLC Jefferies LLC Morgan Stanley & Co. LLC As Representatives of the several Underwriters GOLDMAN SACHS & CO. LLC /s/ Danielle Freeman Name: Danielle Freeman Title: Managing Director JEFFERIES LLC /s/ Michael Bauer Name: Michael Bauer Title: Managing Director MORGAN STANLEY & CO. LLC /s/ Daniel Croitoru Name: Daniel Croitoru Title: Vice President [Signature Page to Underwriters’ Acceleration Request]