SecProbe.io

November 4, 2024
Nicolas Lin
Chief Executive Officer
Aether Holdings, Inc.
1441 Broadway, 30th Floor
New York, NY 10018
Re:Aether Holdings, Inc.
Amendment No. 2 to Draft Registration Statement on Form S-1
Submitted October 18, 2024
CIK No. 0002026353
Dear Nicolas Lin:
            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 August 26, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form S-1
Management's Discussion and Analysis of financial Condition and Results of Operations
Free Subscribers, page 41
1.Please expand the discussion of the decrease in the number of free subscribers in the
third quarter ended June 30, 2024 to explain the reasons for the significant decrease to
only 216 free subscribers compared to the comparative quarter or the first and second
quarters of fiscal 2024. Please address any trends in fiscal 2024 that might be
indicated by the free subscriber decline in the third quarter.

November 4, 2024
Page 2
Business
Government Regulation, page 65
2.Please expand on your response to prior comment 1 to clarify whether the analysis
presented with respect to the Company’s “financial research products” addresses all of
the Company’s products, including the products described on pages 55-56 of the
prospectus as “Data & Technology services” and “Actionable Strategies.” To the
extent that the provided analysis does not also apply with respect to these products,
please supplement your response to discuss whether the Company believes that these
products do not cause the Company to meet the definition of an investment adviser for
some other reason—and why.
            Please contact Claire DeLabar at 202-551-3349 or Robert Littlepage at 202-551-3361
if you have questions regarding comments on the financial statements and related
matters. Please contact Aliya Ishmukhamedova at 202-551-7519 or Jeff Kauten at 202-551-
3447 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Lawrence A. Rosenbloom, Esq.