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 April 10, 2025

Justin Cohen
Chief Executive Officer
Ategrity Specialty Holdings LLC
9 West 57th Street, 33rd Floor
New York, NY 10019

 Re: Ategrity Specialty Holdings LLC
 Registration Statement on Form S-1
 Filed March 24, 2025
 File No. 333-286059
Dear Justin Cohen:

 We have reviewed your registration statement and have the following
comments.

 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.

Registration Statement on Form S-1
Expense ratio, page 67

1. Please revise to include a detailed discussion which addresses and
quantifies the
 changes and reasons for the changes in policy acquisition costs, and
each of the
 individual operating and general expenses in each individual period
presented.
Loss ratio, page 67

2. Please revise to provide a detailed discussion of the actual losses paid
as well as the
 actuarial impact on the estimated losses on each type of insurance
contract in the
 determination of the loss and loss adjustment expenses in each
individual period
 presented.
 April 10, 2025
Page 2
Results of Operations
Year ended December 31, 2024, compared to year ended December 31, 2023
Premiums, page 67

3. Please revise, for each individual period presented, to discuss the
gross and net
 premiums written and earned in each of the verticals in which you focus,
specifically,
 Real Estate, Hospitality, Construction, and Retail.
Other expenses, page 69

4. Please disclose in MD&A the following information relating to your
equity issuances:

 discussion of the significant factors, assumptions and
methodologies used in
 determining fair value;
 discussion of each significant factor contributing to the
difference between the fair
 value as of the date of each grant and the estimated IPO price;
 the valuation alternative selected and, if applicable, the reason
management chose
 not to obtain contemporaneous valuation by an unrelated valuation
specialist; and
 the intrinsic value of outstanding vested and unvested options
based on the
 estimated IPO price and the options outstanding as of the most
recent balance
 sheet date presented in your registration statement.
Financial Condition
Investment portfolio, page 74

5. Please revise to provide investment portfolio information for the 2023
fiscal period
 similar to the information provided for the 2024 fiscal period.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Victor Cecco at 202-551-2064 or Marc Thomas at
202-551-3452 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Robert Arzonetti at 202-551-8819 or Susan Block at 202-551-3210 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
 April 10, 2025
Page 3
cc: Erika L. Weinberg
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