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 May 13, 2025

Jason Kim
Chief Executive Officer
Firefly Aerospace Inc.
1320 Arrow Point Drive #109
Cedar Park, TX 78613

 Re: Firefly Aerospace Inc.
 Draft Registration Statement on Form S-1
 Submitted April 16, 2025
 CIK No. 0001860160
Dear Jason Kim:

 We have reviewed your draft registration statement and have the following
comment(s).

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1 filed April 16, 2025
Prospectus Summary, page 1

1. Please balance the disclosure in your summary by prominently disclosing
your level
 of indebtedness, history of losses, and other challenges you face.
Business, page 97

2. We note your disclosure that the MLV is in final development in
partnership with
 Northrop Grumman and that you expect the first launch to take place from
Virginia s
 Mid-Atlantic Regional Spaceport on Wallops Island. Please revise to
disclose
 anticipated timing of your MLV launch and/or first delivery.
 May 13, 2025
Page 2

Intellectual Property, page 109

3. Please disclose the duration and effect of all patents, trademarks,
licenses, franchises,
 and concessions held. Refer to Item 101(c) of Regulation S-K.
Regulatory, page 109

4. Please revise your disclosure in this section to describe the material
effects that
 compliance with government regulations may have upon your capital
expenditures,
 earnings and competitive position. Please also address international
regulations
 related to your business.
Index to Consolidated Financial Statements, page F-1

5. Please note the updating requirements of Rule 8-08 of Regulation S-X.
Note 18. Segment and Geographical Information, page F-52

6. You disclose on page F-52 that you did not recognize revenue outside of
the United
 States as of December 31, 2024; however, you disclose on page 55 that a
substantial
 portion of your revenue is generated from customers outside of the
United States.
 Please address this apparent discrepancy and ensure future disclosures
are revised as
 appropriate.
General

7. Please provide us supplemental copies of all written communications, as
defined in
 Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your
 behalf, have presented or expect to present to potential investors in
reliance on Section
 5(d) of the Securities Act, whether or not you retained or intend to
retain copies of
 these communications. Please contact legal staff associated with the
review of this
 filing to discuss how to submit the materials, if any, to us for review.
8. We note that one customer accounted for 58% of your revenues in 2024.
Please
 disclose terms of your material agreements file all material agreements
as exhibits to
 your registration statement. If you believe you are not substantially
dependent on any
 such agreement, please explain why. Refer to Item 601(b)(10) of
Regulation S-K.
 Please contact Jeff Gordon at 202-551-3866 or Melissa Gilmore at
202-551-3777 if
you have questions regarding comments on the financial statements and related
matters. Please contact Bradley Ecker at 202-551-4985 or Asia Timmons-Pierce at
202-551-
3754 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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