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Correspondence 0001641172-25-002986 from Aether Holdings, Inc. (ATHR)

Aether Holdings, Inc.
Date: April 7, 2025 · CIK: 0002026353 · Accession: 0001641172-25-002986

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File numbers found in text: 333-284081

Date
April 7, 2025
Author
Chief
Form
CORRESP
Company
Aether Holdings, Inc.

Letter

April 7, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

F Street, N.E.

Washington, DC 20549

Attention: Nicholas O'Leary

Attention:

Aliya Ishmukhamedova

Jeff Kauten

Claire DeLabar

Robert Littlepage

Re: Aether Holdings, Inc.

Registration Statement on Form S-1

Initially filed December 30, 2024, as amended

File No. 333-284081

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the "Securities Act"), we, as representatives of the underwriters of the proposed initial public offering of securities of Aether Holdings, Inc. (the "Company"), hereby join the Company's request that the effective date of the above-referenced Registration Statement on Form S-1 be accelerated so that it will be declared effective at 4:30 p.m., Eastern Time, on Wednesday, April 9, 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 Securities and Exchange Commission.

Pursuant to Rule 460 under the Securities Act, we, as representatives of the underwriters, wish to advise you that there will be distributed to each underwriter, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advise that they have complied and will continue to comply, and that they have been informed by the participating underwriters that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Remainder of Page Intentionally Left Blank]

Very
truly yours,
The
Benchmark Company, LLC

Show Raw Text
CORRESP
 1
 filename1.htm

 April
7, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F Street, N.E.

 Washington,
DC 20549

 Attention:
Nicholas O'Leary

 Attention:

 Aliya
 Ishmukhamedova

 Jeff
 Kauten

 Claire
 DeLabar

 Robert
 Littlepage

 Re:
 Aether
 Holdings, Inc.

 Registration
 Statement on Form S-1

 Initially
 filed December 30, 2024, as amended

 File
 No. 333-284081

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the "Securities Act"), we, as
representatives of the underwriters of the proposed initial public offering of securities of Aether Holdings, Inc. (the "Company"),
hereby join the Company's request that the effective date of the above-referenced Registration Statement on Form S-1 be accelerated
so that it will be declared effective at 4:30 p.m., Eastern Time, on Wednesday, April 9, 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 Securities and Exchange
Commission.

 Pursuant
to Rule 460 under the Securities Act, we, as representatives of the underwriters, wish to advise you that there will be distributed to
each underwriter, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form
of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

 The
undersigned advise that they have complied and will continue to comply, and that they have been informed by the participating underwriters
that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934,
as amended.

 [Remainder
of Page Intentionally Left Blank]

 Very
 truly yours,

 The
 Benchmark Company, LLC

 By:
 /s/
 Michael S. Jacobs

 Name:
 Michael S. Jacobs

 Title:
 Head of Equity Capital
 Markets

 Axiom
 Capital Management, Inc.

 By:
 /s/Liam
 Dalton

 Name:
 Liam
 Dalton

 Title:

 Chief
 Executive Officer

 cc:
 Richard A. Friedman, Sheppard, Mullin, Richter &
 Hampton LLP

 Ellenoff Grossman & Schole LLP