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CORRESP Filing

Bluemount Holdings Ltd
Date: May 23, 2025 · CIK: 0002027815 · Accession: 0002027815-25-000009

Capital Structure Offering / Registration Process Regulatory Compliance

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File numbers found in text: 333-285843

Date
May 23, 2025
Author
/s/ Lawrence S. Venick
Form
CORRESP
Company
Bluemount Holdings Ltd

Letter

Submission Proof - Z:\2023 OPERATIONS\2023 EDGAR\08 August\E I L HOLDINGS LIMITED\08-30-2023\Form DRSLTR\Draft\Production\E I L HOLDINGS LIMITED 08-30-2023 Form DRSLTR.gfp May 23, 2025 Division of Corporate Finance, Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549

Re: Bluemount Holdings Limited

Dear SEC Officers,

Submission of Amended DRS Following Share Surrender

Filed May 23, 2025

File No. 333-285843

On behalf of Bluemount Holdings Limited (the “Company”), we hereby submit the amended Draft Registration Statement (DRS) for your review. This amendment reflects the recent surrender of an aggregate of 11,505,152 Class A Ordinary Shares and 12,500,001 Class B Ordinary Shares, which were accepted by the Company for no consideration and subsequently cancelled upon surrender.

The surrender was primarily driven by valuation considerations, ensuring that the Company maintains a sound capital structure and optimizes shareholder value in alignment with market conditions. In light of this, we have incorporated the relevant updates to the shareholdings and F-pages within the amended DRS, ensuring full transparency and accuracy of the filing.

Given that the audits will become stale on June 30, 2025, the Company sincerely hopes to receive a "no further comments" confirmation from the SEC and Nasdaq in a timely manner. This will allow our underwriter to proceed with book-building at the earliest opportunity and, ideally, close the project by June 30, 2025.

Your prompt attention to this matter would be greatly appreciated. Please do not hesitate to reach out if any further clarifications or additional information are required.

Thank you for your time and consideration.

Very truly yours,
/s/ Lawrence S. Venick

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CORRESP
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 Submission Proof - Z:\2023 OPERATIONS\2023 EDGAR\08 August\E I L HOLDINGS LIMITED\08-30-2023\Form DRSLTR\Draft\Production\E I L HOLDINGS LIMITED 08-30-2023 Form DRSLTR.gfp

 May 23, 2025

 Division of Corporate Finance,
 Securities and Exchange Commission
 100 F Street, N.E.
 Washington, D.C. 20549

 Dear SEC Officers,

 Re:
 Bluemount Holdings Limited

 Submission of Amended DRS Following Share Surrender

 Filed May 23, 2025

 File No. 333-285843

 On behalf of Bluemount Holdings Limited (the “Company”), we hereby submit the amended Draft Registration Statement (DRS) for your review. This amendment reflects the recent surrender of an aggregate of 11,505,152 Class A Ordinary Shares and 12,500,001 Class B Ordinary Shares, which were accepted by the Company for no consideration and subsequently cancelled upon surrender.

 The surrender was primarily driven by valuation considerations, ensuring that the Company maintains a sound capital structure and optimizes shareholder value in alignment with market conditions. In light of this, we have incorporated the relevant updates to the shareholdings and F-pages within the amended DRS, ensuring full transparency and accuracy of the filing.

 Given that the audits will become stale on June 30, 2025, the Company sincerely hopes to receive a "no further comments" confirmation from the SEC and Nasdaq in a timely manner. This will allow our underwriter to proceed with book-building at the earliest opportunity and, ideally, close the project by June 30, 2025.

 Your prompt attention to this matter would be greatly appreciated. Please do not hesitate to reach out if any further clarifications or additional information are required.

 Thank you for your time and consideration.

 Very truly yours,

 /s/ Lawrence S. Venick

 Lawrence S. Venick