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September 25, 2023          

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attn: Robert Arzonetti and Susan Block

    Re:
    Calculator New Pubco, Inc.

    Amendment No. 4
    to

    Registration Statement
    on Form S-4

    Filed September 6, 2023

    File No. 333-271665

Dear Mr. Arzonetti and Ms. Block:

On behalf of Calculator New Pubco, Inc. (the
 “Company”), we are hereby responding to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange
Commission set forth in your letter dated September 22, 2023 (the “Comment Letter”) with respect to the above referenced
Amendment No. 4 to the Registration Statement on Form S-4, filed by the Company on September 6, 2023.

The Company has filed via EDGAR Amendment No. 5
to the Registration Statement on Form S-4 (“Amendment No. 5 to the Registration Statement”), which reflects
the Company’s responses to the comments received by the Staff and certain updated information. For ease of reference, the text
of each of the Staff’s comments, as set forth in the Comment Letter, is included in bold-face type below, followed by the Company’s
response. All page references in the responses set forth below refer to page numbers in Amendment No. 5 to the Registration
Statement. Capitalized terms used but not defined herein have the meanings set forth in Amendment No. 5 to the Registration Statement.

Amended Form S-4 Filed September 6, 2023

Risk Factors

Wilson-Davis will need to obtain additional capital to meet
increased excess capital

requirements, page 51

 1. We note your disclosure that Wilson-Davis will need to obtain
                                            additional capital to meet increased capital requirements in order to continue to clear for
                                            an introducing broker. Please expand to explain how not meeting this additional capital requirement
                                            may impact Wilson-Davis's business so that investors can assess the risk. For instance, please
                                            explain how much revenue the company received last year from this aspect of the business,
                                            and what percentage of revenue that was.

Response:
In response to the Staff’s comment, the disclosure on page 51 of Amendment No. 5 to the Registration Statement has been
revised.

September 25, 2023

Page 2

Updated Projections, page 112

 2. We note your response to comment 1 and reissue in part. You
                                            state the Updated Projections reflect "...reduced projections for increase in customers
                                            and brokers in the first two years..." even though the Year 2 Updated Projections for
                                            total revenue are higher than those for the Initial Projections. Please revise your disclosure
                                            to clarify.

Response:
In response to the Staff’s comment, the disclosure on page 113  of Amendment No. 5 to the Registration Statement has been
revised.

Wilson-Davis & Co., Inc Audited Financial Statements,
page F-49

 3. Please revise to include the Report of Independent Registered
                                            Public Accounting Firm for the audited financial statements presented for Wilson-Davis &
                                            Co.

Response:
In response to the Staff’s comment, the Report of Independent Registered Public Accounting Firm for the audited financial statements
presented for Wilson-Davis & Co. has been included on page F-49 of Amendment No. 5 to the Registration Statement.

We thank the Staff in advance for its consideration
of the foregoing. If you have any questions related to this letter, please contact the undersigned at (703) 749-1386.

    Sincerely,

    /s/ Jason Simon

    Jason Simon

    cc:
    Robert McBey – Chief Executive Officer