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CORRESP Filing

Bullish
Date: Aug. 11, 2025 · CIK: 0001872195 · Accession: 0001104659-25-075907

Offering / Registration Process

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File numbers found in text: 333-288780

Date
August 11, 2025
Author
LLC
Form
CORRESP
Company
Bullish

Letter

Re: Bullish

August 11, 2025

VIA EDGAR

U.S. Securities and Exchange Commission Division of Corporation Finance

100 F Street, N.E. Washington, D.C. 20549

Attn: David Gessert

J. Nolan McWilliams

Acceleration Request for Bullish

Registration Statement on Form F-1

File No. 333-288780

Ladies and Gentlemen:

We refer to the registration statement on Form F-1 (File No. 333-288780) (as amended, the " Registration Statement "), of Bullish (the " Company "), relating to the registration of the Company's ordinary shares, nominal value $0.002 per share.

In accordance with Rules 460 and 461 under the Securities Act of 1933, as amended, (the " Act ") we, as representatives of the several underwriters (the " Underwriters "), hereby respectfully request that the effectiveness of the Registration Statement be accelerated so that it may become effective at 4:00 P.M. (Eastern time) on August 12, 2025, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance 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 we will take reasonable steps to secure adequate distribution of the preliminary prospectus to 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,
J.P. MORGAN SECURITIES LLC JEFFERIES
LLC

Show Raw Text
CORRESP
 1
 filename1.htm

 August 11, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission
Division of Corporation Finance

 100 F Street, N.E.
Washington, D.C. 20549

 Attn:
 David Gessert

 J. Nolan McWilliams

 Re:
 Bullish

 Acceleration
 Request for Bullish

 Registration
 Statement on Form F-1

 File No. 333-288780

 Ladies and Gentlemen:

 We refer to the registration statement on Form F-1
(File No. 333-288780) (as amended, the " Registration Statement "), of Bullish (the " Company "),
relating to the registration of the Company's ordinary shares, nominal value $0.002 per share.

 In accordance with Rules 460 and 461 under
the Securities Act of 1933, as amended, (the " Act ") we, as representatives of the several underwriters (the " Underwriters "),
hereby respectfully request that the effectiveness of the Registration Statement be accelerated so that it may become effective at 4:00
P.M. (Eastern time) on August 12, 2025, or at such later time as the Company or its counsel may orally request via telephone
call to the staff of the Division of Corporation Finance 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 we will take reasonable steps to secure adequate distribution of
the preliminary prospectus to 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,

 J.P. MORGAN SECURITIES LLC JEFFERIES
 LLC

 As representatives of the several
 underwriters

 J.P. MORGAN SECURITIES LLC

 By:
 /s/
Alaoui Zenere

 Name: Alaoui Zenere

 Title: Managing Director

 JEFFERIES LLC

 By:
 /s/ Kevin Lacerda

 Name: Kevin Lacerda

 Title: Managing Director

 [ Signature Page to Acceleration Request ]