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 March 27, 2025

Michael Klein
Chief Executive Officer
Churchill Capital Corp X
640 Fifth Avenue, 14th Floor
New York, NY 10019

 Re: Churchill Capital Corp X
 Amendment No. 2 to
 Draft Registration Statement on Form S-1
 Submitted March 6, 2025
 CIK No. 0002007825
Dear Michael Klein:

 We have reviewed your amended draft registration statement and have the
following
comments.

 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. Unless we note otherwise, any references to prior comments are to
comments in
our June 20, 2024 letter.

Amended Draft Registration Statement on Form S-1
Sponsor Information, page 11

1. We note your disclosure on page 12 that the Strategic Partners and
Operating Partners
 may invest in your sponsor but will have no right to control the sponsor
or participate
 in any decision regarding the disposal of any security held by the
sponsor. Please
 disclose the persons if any who may have direct and indirect material
interests in the
 sponsor, as well as the nature and amount of their interests. See Item
1603(a)(7) of
 Regulation S-K.
 March 27, 2025
Page 2

The Offering
Founder Shares, page 23

2. Please expand your disclosure on pages 22, 33, 142, and elsewhere as
appropriate, to
 clarify whether any public shares sold in this offering would be
required to approve
 the business combination if the minimum to constitute a quorum is
present at the
 meeting. Please also revise your Risk Factors as appropriate or
otherwise advise.
Dilution, page 107

3. Please expand your disclosure outside the table to highlight that you
may need to issue
 additional securities as you intend to seek an initial business
combination with a target
 company with an enterprise value greater than the net proceeds of the
offering and the
 sale of private placement warrants, as stated on page 11 of your
prospectus.
Management, page 161

4. Please include more detailed disclosure regarding any SPAC experience
your sponsor,
 affiliates, management may have. Please revise to disclose further
information
 concerning any completed business combinations, including the financing
needed for
 the transactions and the level of redemptions. Also, disclose any
extensions and
 redemption levels in connection with an extension. See Item 1603(a)(3)
of Regulation
 S-K.
 Please contact Jeffrey Lewis at 202-551-6216 or Isaac Esquivel at
202-551-3395 if
you have questions regarding comments on the financial statements and related
matters. Please contact Ruairi Regan at 202-551-3269 or Jeffrey Gabor at
202-551-2544 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Stuart Neuhauser, Esq.
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