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CORRESP Filing

Bullish
Date: Aug. 11, 2025 · CIK: 0001872195 · Accession: 0001104659-25-075906

Offering / Registration Process

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File numbers found in text: 333-288780

Date
August 11, 2025
Author
Bullish
Form
CORRESP
Company
Bullish

Letter

Bullish

10A Building A, 60 Nexus Way, Camana Bay, George Town, Grand Cayman, Cayman Islands, KY1-9005

August 11, 2025

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attention: David Gessert, J. Nolan McWilliams

Re: Bullish Registration Statement on Form F-1 File No. 333-288780

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, Bullish (the "Registrant") respectfully requests that the effective date of the above-referenced Registration Statement on Form F-1 (as amended, the "Registration Statement") be accelerated so that the same will become effective at 4:00 PM ET on August 12, 2025, or as soon thereafter as is practicable. By separate letter, the underwriters for the offering to which the Registration Statement relates join in this request for acceleration.

The Registrant hereby authorizes Howard A. Kenny and Erin E. Martin, of Morgan, Lewis & Bockius LLP to orally modify or withdraw this request for acceleration.

Please contact Howard A. Kenny at +1.212.309.6843 or howard.kenny@morganlewis.com or Erin E. Martin at +1.202.739.5729 or erin.martin@morganlewis.com with any questions you may have concerning this request, and please notify them when this request for acceleration has been granted.

Very truly yours,
Bullish

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CORRESP
 1
 filename1.htm

 Bullish

 10A Building A, 60 Nexus Way, Camana Bay,
George Town, Grand Cayman, Cayman Islands, KY1-9005

 August 11, 2025

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

 Attention: David Gessert, J. Nolan McWilliams

 Re: Bullish
 Registration Statement on Form F-1
 File No. 333-288780

 Ladies and Gentlemen:

 In accordance with Rule 461 under the
Securities Act of 1933, as amended, Bullish (the "Registrant") respectfully requests that the effective date of the
above-referenced Registration Statement on Form F-1 (as amended, the "Registration Statement") be accelerated so that the same will
become effective at 4:00 PM ET on August 12, 2025, or as soon thereafter as is practicable. By separate letter, the underwriters for the offering to which the Registration Statement relates join in this request for acceleration.

 The Registrant hereby authorizes Howard A. Kenny
and Erin E. Martin, of Morgan, Lewis & Bockius LLP to orally modify or withdraw this request for acceleration.

 Please contact Howard A. Kenny at +1.212.309.6843
or howard.kenny@morganlewis.com or Erin E. Martin at +1.202.739.5729 or erin.martin@morganlewis.com with any questions you may have concerning
this request, and please notify them when this request for acceleration has been granted.

 Very truly yours,

 Bullish

 By:
 /s/ Thomas W. Farley

 Name:
 Thomas W. Farley

 Title:
 Chief Executive Officer