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SEC Company Response from DAVION HEALTHCARE (DAVI) — Oct 20, 2025

DAVION HEALTHCARE PLC
Date: Oct. 20, 2025 · CIK: 0002039072 · Accession: 0001683168-25-007659

Offering / Registration Process Regulatory Compliance Financial Reporting

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File numbers found in text: 333-289205

Date
September 26, 2025
Author
/s/ Jack Kaye
Form
CORRESP
Company
DAVION HEALTHCARE PLC

Letter

Division of Corporation Finance Office of Industrial Applications and Services Cc: David E Price – Attorney at Law Re: Davion Healthcare plc SEC Staff: Tayaba Shafique, Li Xiao, Conlon Danberg Registration Statement on Form F-1/A (File No. 333-289205) Filed: September 26, 2025

Dear Mr Grana,

Subject: Request for Acceleration of Effectiveness under Rule 461

Pursuant to Rule 461 under the Securities Act of 1933, Davion Healthcare plc (the "Company") respectfully requests that the Commission declare effective the Company's Registration Statement on Form F-1, as amended, as soon as practicable following the resumption of normal Commission operations.

The Company confirms that the Registration Statement relates to a direct listing of the Company's ordinary shares on the NASDAQ Stock Market, and that no underwriters are involved in connection with the listing. Accordingly, no distribution of a preliminary prospectus under Rule 460 is required or applicable.

Should the Staff determine that the Company's responses filed in F-1/A on September 26, 2025, satisfactorily address all outstanding comments, the Company respectfully requests that the Registration Statement be declared effective at the Staff's earliest convenience.

As stated in the Company's email correspondence of the same date, immediately upon effectiveness the Company will furnish a Form 6-K containing its unaudited interim condensed consolidated financial statements for the six-month period ended June 30, 2025, together with related Management's Discussion and Analysis, to ensure its public disclosures remain current.

The Company appreciates the Staff's continued attention to this matter and stands ready to provide any supplemental information necessary to facilitate effectiveness.

Respectfully submitted,
/s/ Jack Kaye

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CORRESP
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 filename1.htm

 Davion Healthcare Plc

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial Applications and Services

 100 F Street, N.E.
 Via EDGAR and Email

 Washington, D.C. 20549

 Attn: Mr Juan Grana

 20th October 2025

 Cc: David E Price – Attorney at Law

 Re: Davion Healthcare plc
 SEC Staff: Tayaba Shafique, Li Xiao, Conlon
Danberg

 Registration Statement on Form F-1/A (File No. 333-289205)

 Filed: September 26, 2025

 Dear Mr Grana,

 Subject: Request for Acceleration of Effectiveness under Rule 461

 Pursuant to Rule 461 under the Securities Act of 1933, Davion Healthcare
plc (the "Company") respectfully requests that the Commission declare effective the Company's Registration Statement
on Form F-1, as amended, as soon as practicable following the resumption of normal Commission operations.

 The Company confirms that the Registration Statement relates to a direct
listing of the Company's ordinary shares on the NASDAQ Stock Market, and that no underwriters are involved in connection with the
listing. Accordingly, no distribution of a preliminary prospectus under Rule 460 is required or applicable.

 Should the Staff determine that the Company's responses filed
in F-1/A on September 26, 2025, satisfactorily address all outstanding comments, the Company respectfully requests that the Registration
Statement be declared effective at the Staff's earliest convenience.

 As stated in the Company's email correspondence of the same
date, immediately upon effectiveness the Company will furnish a Form 6-K containing its unaudited interim condensed consolidated
financial statements for the six-month period ended June 30, 2025, together with related Management's Discussion and Analysis,
to ensure its public disclosures remain current.

 The Company appreciates the Staff's continued attention to this
matter and stands ready to provide any supplemental information necessary to facilitate effectiveness.

 Respectfully submitted,

 /s/ Jack Kaye

 Jack Kaye

 Chief Executive Officer

 jack.kaye@davionhealthcare.com

 +44 7429 654321

 Davion
 Healthcare Plc
 The
 Cube
 Monahan
 Road
 Cork
 T12
 H1XY
 Ireland

 T:
 +353 21 212 9330

 info@davionhealthcare.com
 www.davionhealthcare.com

 Registered
in Ireland under Company Registration Number 772522

 Registered
Office: MC2 Accountants, Penrose Wharf, Penrose Quay, Cork, T23 XN53, Ireland