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 April 16, 2025

Deven Soni
President and Chief Executive Officer
Vertical Data Inc.
1980 Festival Plaza Drive Suite 300
Las Vegas, NV 89135

 Re: Vertical Data Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed March 20, 2025
 File No. 333-284187
Dear Deven Soni:

 We have reviewed your amended registration statement and have the
following
comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our February 7,
2025 letter.

Amendment No. 1 to Registration Statement on Form S-1 filed March 20, 2025
Prospectus Summary
Our Products and Suppliers, page 2

1. We note your response to prior comment 3, including the statement that
you have two
 vendor arrangements but "do not have any material agreements with a
vendor." Please
 briefly revise your disclosure to clarify the meaning of "arrangements"
(e.g., written
 contracts or otherwise). Additionally, we note that you entered into a
master sales
 agreement with suppliers, including "key partner" Sycomp. Please revise
to include
 the material terms of this agreement and file it as an exhibit or tell
us why you are not
 required to do so. Refer to Item 601(b)(10) of Regulation S-K.
 April 16, 2025
Page 2
The Offering, page 7

2. We note your response to prior comment 18, including the revisions to
footnote 2 to
 your Selling Stockholder table on page 31. Please revise your "Lock-Up"
disclosure
 here and elsewhere as appropriate to reflect the holding period of a
total of thirty-six
 (36) months from the date of the offering as well as the twelve (12)
month period
 holding period on the shares and, following the first year, how the
restrictions on the
 shares will be proportionally removed monthly thereafter with regard to
the shares
 held by the Founders.
Risk Factors
Risks Related to Our Business
Our business is subject to a wide variety of extensive and evolving government
regulations...,
page 13

3. We note your revised disclosure in response to prior comment 6,
including that this
 risk factor references "nuclear-fuel related products." To the extent
you have
 operations in nuclear fuel industry, please revise as appropriate.
Alternatively, please
 remove this reference.
Exhibit Index, page II-5

4. The consent of your independent registered public accounting firm filed
as exhibit
 23.1 does not appear to be signed. Please ensure future amendments
include a signed
 consent.

 Please contact James Giugliano at 202-551-3319 or Theresa Brillant at
202-551-3307
if you have questions regarding comments on the financial statements and
related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Cara Wirth at
202-551-7127
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Scott E. Linsky
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