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    WeShop
                                            Holdings Limited

    Hawk
    House

    22
    The Esplanade

    Jersey,
    JE1 1HH

    Channel
    Islands

    https:\\we.shop

    Paul
    Ellerbeck

    paul.ellerbeck@we.shop

September
15, 2025

VIA
EDGAR AND OVERNIGHT COURIER

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, NE

Washington,
D.C. 20549

Attention:
Adam Phippen

Kate
Beukenkamp

Taylor
Beech

    Re:
    WeShop
                                            Holdings Limited

    Amendment
    No. 5 to Draft Registration Statement on Form F-1

    Submitted
    August 19, 2025

    CIK
    No. 0002048271

Ladies
and Gentlemen:

This
letter is submitted by WeShop Holdings Limited (“we” or the “Company”) in response
to comments of the staff of the U.S. Securities and Exchange Commission (the “Staff”) with respect to the Company’s
Amendment No. 5 to the Draft Registration Statement on Form F-1 confidentially submitted on August 19, 2025 (the “Amendment
No. 5 to the Draft Registration Statement”), as set forth in the Staff’s letter dated August 29, 2025 (the “Comment
Letter”).

Set
forth below are the Company’s responses to the Staff’s comments in the Comment Letter. For reference purposes, the text of
the Staff’s comments is reproduced in bold below, followed by the Company’s response to the comment. The numbered paragraphs
below correspond to the numbered comments in the Comment Letter.

Additionally,
the Company is concurrently filing a registration statement (the “Registration Statement”), which reflects
revisions in response to the Comment Letter and certain other updates. For the convenience of the Staff, we are also sending, by overnight
courier, copies of this letter and copies of the Registration Statement marked to show changes to the Amendment No. 5 to the Draft Registration
Statement.

Amendment
No. 5 on Form F-1

Related
Party Transactions

Consulting
Agreement, page 78

1.
We note your response to prior comment 5. Please further revise your disclosure here and elsewhere as appropriate to make clear whether
this strategic consulting agreement remains in effect, the duration of this agreement, and whether this entity is still controlled by
John Garner, your Head of Visions and Strategy. We note that the company “owes an additional 91,000 shares as outlined in the agreement...”
and that Max Capital is a beneficial owner. Additionally, please consider whether to file this agreement under Item 601(b)(10) of Regulation
S-K.

Company
Response: In response to the Staff’s comment, in the Registration Statement clarified the details of the Max Capital Limited
agreement and John Garner’s control over that entity. The agreement is terminated so we have not filed it.

Description
of Shares and Memorandum and Articles of Association Share Rights, page 80

2.
Please include a comparable description of the Class B ordinary shares as you have provided for the Class A ordinary shares. Clarify,
if true, that the Trust will be the sole holder of Class B ordinary shares.

Company
Response: In response to the Staff’s comment, we have described the Class B ordinary shares and clarified that the Trust will
be the sole holder of these shares.

Should
the Staff have additional questions or comments regarding this submission, please do not hesitate to contact the undersigned at paul.ellerbeck@we.shop
or Christian Nagler of Kirkland & Ellis LLP at +1 (212) 446-4660.

Remainder
of page intentionally blank. Signature page follows.

    Sincerely,

    WESHOP HOLDINGS LIMITED

    /s/
    Paul Ellerbeck

    Name:
    Paul
    Ellerbeck

    Title:
    Chief
    Executive Officer

Enclosure

cc:
Christian O. Nagler, P.C.

Kirkland
& Ellis LLP

John
Garner

WeShop
Holdings Limited