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Correspondence 0001193125-26-239401 from Firefly Aerospace Inc. (FLY)

Firefly Aerospace Inc.
Date: May 26, 2026 · CIK: 0001860160 · Accession: 0001193125-26-239401

Offering / Registration Process Regulatory Compliance Business Model Clarity

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Date
May 26, 2026
Author
Goldman Sachs & Co. LLC
Form
CORRESP
Company
Firefly Aerospace Inc.

Letter

Re: Firefly Aerospace Inc. Registration Statement on Form S-1 Filed May 26, 2026 (CIK No. 0001860160) Ladies and Gentlemen: 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 Firefly Aerospace Inc. (the “Company”) that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m. New York City time on Thursday, May 28, 2026 or as soon thereafter as practicable, or at such other time thereafter as the Company or its outside counsel, Kirkland & Ellis LLP, may request by telephone to the staff of the U.S. Securities and Exchange Commission. Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of securities, as many copies of the preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus. We, the undersigned, as representatives of the several underwriters, will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. * * *

Goldman Sachs & Co. LLC 200 West Street New York, New York 10282 J.P. Morgan Securities LLC 270 Park Avenue New York, New York 10017 Jefferies LLC 520 Madison Avenue New York, New York 10022 Wells Fargo Securities, LLC 500 West 33 rd Street, 14 th Floor New York, New York 10001 May 26, 2026 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing 100 F Street, N.E. Washington, D.C. 20549 Attention: Kristin Baldwin

Very truly yours,
Goldman Sachs & Co. LLC J.P. Morgan Securities LLC
Jefferies LLC Wells Fargo Securities, LLC
as representatives of the several underwriters
Goldman Sachs & Co. LLC

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CORRESP
 1
 filename1.htm

 CORRESP

 Goldman Sachs & Co. LLC
 200 West Street New York, New York 10282
 J.P. Morgan Securities LLC 270 Park Avenue
 New York, New York 10017 Jefferies LLC
 520 Madison Avenue New York, New York 10022
 Wells Fargo Securities, LLC 500 West 33 rd Street, 14 th Floor New York, New York 10001
 May 26, 2026 VIA EDGAR
 United States Securities and Exchange Commission Division of
Corporation Finance Office of Manufacturing 100 F Street,
N.E. Washington, D.C. 20549 Attention: Kristin Baldwin

 Re:
 Firefly Aerospace Inc.
 Registration Statement on Form S-1
 Filed May 26, 2026 (CIK
No. 0001860160) Ladies and Gentlemen: 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 Firefly Aerospace Inc. (the “Company”) that the effective
date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m. New York City time on Thursday, May 28, 2026 or as soon thereafter as practicable, or at such other time thereafter as
the Company or its outside counsel, Kirkland & Ellis LLP, may request by telephone to the staff of the U.S. Securities and Exchange Commission.
 Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that there will be distributed to each
underwriter or dealer, who is reasonably anticipated to participate in the distribution of securities, as many copies of the preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus. We,
the undersigned, as representatives of the several underwriters, will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
 * * *

 Very truly yours,
 Goldman Sachs & Co. LLC J.P. Morgan Securities LLC
 Jefferies LLC Wells Fargo Securities, LLC
 as representatives of the several underwriters

 Goldman Sachs & Co. LLC

 By:

 /s/ Ryan Cunn

 Name: Ryan Cunn

 Title: Managing Director

 J.P. Morgan Securities LLC

 By:

 /s/ Arun Kumarathas

 Name: Arun Kumarathas

 Title: Executive Director

 Jefferies LLC

 By:

 /s/ Scott Skidmore

 Name: Scott Skidmore

 Title: Managing Director

 Wells Fargo Securities, LLC

 By:

 /s/ Christie MacDonald

 Name: Christie MacDonald

 Title: Managing Director