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CORRESP
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 GrabAGun Digital Holdings Inc.

 214 Brazilian Avenue, Suite 200-J

 Palm Beach, FL 33480

 VIA EDGAR

 April 29, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention:

 Cara Wirth

 Dietrich King

 Scott Stringer

 Suying Li

 Re:
 GrabAGun Digital Holdings Inc.

 Registration Statement on Form S-4

 Filed March 21, 2025

 File No. 333-286021

 Dear Ms. Wirth / Mr. Stringer:

 GrabAGun Digital Holdings
Inc. (" Pubco ") and Metroplex Trading Company LLC (doing business as GrabAGun.com) (" GrabAGun ", and
together with Pubco, the " Co-Registrants " or " we ", " our " or " us "),
hereby submit the Co-Registrants' responses to the comment letter dated April 17, 2025, received from the staff (the " Staff ",
" you " or " your ") of the U.S. Securities and Exchange Commission (the " Commission ")
regarding the Registration Statement on Form S-4 (the " Registration Statement ") submitted to the Commission on March
21, 2025.

 For the Staff's convenience,
we have repeated below the Staff's comment in bold and have followed each comment with the Co-Registrants' response. In response
to the Staff's comments, the Co-Registrants are filing via Edgar a revised draft registration statement (the " Amended Registration
Statement ") simultaneously with the submission of this response letter. Capitalized terms used but not defined in this correspondence
have the meanings set forth in the Amended Registration Statement.

 Registration Statement on Form S-4 Filed March 21, 2025

 Cover Page

 1. Here
and in the prospectus summary, please revise to include the Colombier sponsor compensation. Please refer to Items 1602(a)(3), 1604(a)(3),
and 1604(b)(4) of Regulation S-K.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on pages 17,
124 and the letter to shareholders of the Amended Registration Statement to include the requested information.

 2. We
note in the ninth paragraph you disclose the Colombier board determined the transactions were in the best interests of Colombier. Please
disclose here whether the Colombier board also determined that the transactions were advisable and in the best interests of its security
holders. Please refer to Item 1606(a) of Regulation S-K.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on pages 34, 37 and 87 of the Amended Registration Statement to include the requested information.

 Questions and Answers About the Colombier
Extraordinary General Meeting

 Dilution, page xxiii

 3. We
note your disclosure here and elsewhere of the net tangible book value per share, as adjusted, for the following redemption scenarios
– Assuming No Redemptions, Assuming 50% of Contractual Maximum Redemptions, and Assuming Contractual Maximum Redemptions. Please
expand your disclosure to include at least four redemption scenarios that will reasonably inform investors of potential outcomes or explain
why your scenarios constitute a sufficient range. Refer to Item 1604(c) of Regulation S-K and footnote 277 of SEC Release No. 33-11265.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on page xxii
of the Amended Registration Statement (as well as each other instance in the Amended Registration Statement disclosure in which multiple
redemption scenarios are presented) to include in the disclosure an additional redemption scenario assuming 25% of Contractual Maximum
Redemptions.

 4. Please
revise the title of the line items "net tangible book value per share as of December 31, 2024" disclosed in your dilution
tables on page xxiii to describe the adjusted amounts as "net tangible book value per share, as adjusted, as of December 31, 2024."
Refer to Item 1604(c) of Regulation S-K.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on pages xxiii
and xxiv of the Amended Registration Statement to include the requested information.

 5. We
note your numerator adjustment for transaction expenses incurred by Colombier of $469 thousand. It appears the $469 thousand represents
an amount already reflected in the historical financial statements. See pro forma adjustment D on page 65. If so, please explain (i)
your inclusion of the adjustment and (ii) why it represents an increase to the numerator. Additionally, we note transaction expenses
of $3,646 thousand that have not yet been reflected in the historical financial statements. Please explain why the numerator has not
been adjusted to reflect the expected incurrence of such expenses. Refer to Item 1604(c) of Regulation S-K.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on page xxiv
of the Amended Registration Statement to exclude the $469 thousand in transaction expenses incurred by Colombier to date as a numerator
adjustment. Additionally, we have included $3,646 thousand in transaction expenses to be incurred by Colombier as a numerator adjustment
in the calculation of the as adjusted net tangible book value.

 Summary of the Proxy Statement/Prospectus,
page 1

 6. Please
revise to disclose the background and material terms of the business combination. Refer to Item 1604(b)(1) of Regulation S-K. Additionally,
please disclose the material factors that the Colombier board considered in making the determination to approve the business combination.
Refer to Item 1604(b)(2) of Regulation S-K.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on pages 10
through 14 of the Amended Registration Statement to include the requested information.

 2

 Risk Factors

 There is no assurance that Colombier's diligence
will reveal..., page 22

 7. We
note your statement that "[i]n addition, charges of this nature may cause Pubco to violate leverage or other covenants to which
it may be subject as a result of any financing that may be obtained following the Closing." To the extent that there is any currently
anticipated financing, please revise to state as much, include the material terms and file any agreement as an exhibit. Please refer
to Items 1602(b)(5) and 1604(b)(5) of Regulation S-K and Item 601(b)(10) of Regulation S-K.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on page 30
of the Amended Registration Statement to provide further clarification intended to be responsive to the Staff's comment. As of the
date of the Amended Registration Statement, are no financing transactions identified or expected to be consummated in connection with
the proposed Business Combination.

 Unaudited Pro Forma Condensed Combined Financial
Information, page 62

 8. Please
include, as a separate column in the pro forma financial statements, the historical financials of GrabAGun Digital Holdings Inc. (Pubco)
showing its capital structure before and after the transaction. See Article 11 of Regulation S-X.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure of the Amended Registration Statement to include a separate column presenting the historical financial statements of Pubco.

 9. Please
tell us whether the $2.5 million transaction advisory service agreement fee disclosed in Note 9. Subsequent Events, on page F-40, has
been given pro forma effect. If not, tell us why not.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that pro forma adjustment (F) on the balance sheet reflects estimated
future transaction costs for GrabAGun totaling $3.6 million, which is inclusive of the $2.5 million transaction advisory service agreement
fee.

 Unaudited Pro Forma Condensed Combined Balance
Sheet, page 65

 10. Refer
to pro forma adjustments (G) and (H). Please tell us why it is appropriate to record the payment of $50 million Aggregate Cash Consideration
and the issuance of $100 million Aggregate Stock Consideration as reductions to additional paid in capital.

 Response: The Co-Registrants
acknowledge the Staff's comment, and in response, Co-Registrants have outlined below the basis for recording the payment of $50
million Aggregate Cash Consideration and the issuance of $100 million Aggregate Stock Consideration as reductions to Additional Paid-In
Capital ("APIC").

 GrabAGun, identified as the target company
and accounting acquirer, is merging with Colombier, a public shell corporation with nominal net assets that does not meet the definition
of a business under ASC 805. Consequently, the transaction is accounted for as a reverse recapitalization rather than a business combination.
Under this accounting treatment, a reverse recapitalization is considered equivalent to the issuance of stock by the target company in
exchange for the net monetary assets of the public shell corporation, accompanied by a recapitalization. The accounting for this transaction
follows the same principles as a reverse acquisition, with the exception that no goodwill or other intangible assets are recorded. As
a result, the transaction is effectively accounted for as though GrabAGun issued its equity in exchange for the net assets of Colombier.

 The $50 million Aggregate Cash Consideration
and $100 million Aggregate Stock Consideration are presented as reductions to APIC to reflect the net asset adjustment. The $100 million
Aggregate Stock Consideration represents a new issuance of common stock by Pubco, as the target company does not have existing preferred
stock eligible for conversion into Pubco common stock. To capture the full impact of the transaction, pro forma adjustment (H) reflects
the issuance of new common stock. Specifically, the adjustment accounts for an increase in common stock and APIC, along with an offset
to APIC for the fair value of the Aggregate Stock Consideration, which is treated as non-cash consideration.

 3

 Background of the Business Combination,
page 94

 11. We
note that Colombier formally evaluated approximately 50 business combination opportunities and ultimately entered into non-disclosure
agreements with 12 potential target business. Please disclose how you narrowed the group from 50 to 12. Also please disclose how such
introductions were made (for example, introductions via board members, officers, investment advisors, etc.)

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on pages 104
and 105 of the Amended Registration Statement to include the requested information.

 12. We
note your statement that "Colombier and GrabAGun discussed and negotiated various terms contained in the Initial LOI and GrabAGun
proposed revised terms related to, among other things, the aggregate cash consideration to be received by the GrabAGun Members and the
closing condition regarding minimum transaction proceeds to GrabAGun." Please revise to elaborate on how the form of the initial
consideration and $150 million valuation of GrabAGun were determined, including any material discussions or negotiations surrounding
this topic. In this regard, we note you disclose the parties held calls and meetings between October 2, 2024, and October 29, 2024.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on page 106
of the Amended Registration Statement to include the requested information.

 13. We
note that Colombier engaged Williams Mullen as firearms regulatory legal counsel. To the extent that there were any material discussions
regarding such regulatory component, please revise to state as much. We also note that "Colombier management also met with other
business contacts knowledgeable about the firearms industry and reviewed third-party reports and materials about the firearms, ammunitions
and firearms accessories retail sector and about other public companies with similarities to GrabAGun's business." Please
revise to disclose the identity of such contacts to the extent Colombier management relied upon them.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on page 107
of the Amended Registration Statement to include the requested information.

 14. Please
revise to disclose the material nature of discussions that occurred on November 8 and 15, 2024 and revise to state the reasons needed
to extend the exclusivity term of the LOI on December 3, 2024 and again on December 18, 2024. Additionally, please disclose the topic
of any material negotiation between the parties regarding the Ancillary Agreements.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on page 107
of the Amended Registration Statement to include the requested information.

 4

 Colombier Board's Reasons for the Approval
of the Business Combination, page 98

 15. Please
revise to state whether the board considered the consideration, and whether the board determined that such consideration was fair to
shareholders and the transactions were advisable and in the best interests of Colombier and its security holders. Refer to Item 1606(a)
and (b) of Regulation S-K.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on pages 10, 34, 37 and 87
of the Amended Registration Statement to include the requested information.

 16.

 Please revise to state whether or not:

 ● the business combination transaction is structured so that
approval of at least a majority of unaffiliated security holders of Colombier is required; and

 ● a majority of the Colombier board who are not employees
of Colombier retained an unaffiliated representative to act solely on behalf of unaffiliated security holders for purposes of negotiating
the terms of the business combination and/or preparing a report concerning the approval of the business combination transaction.

 Refer to Item 1606(c) and (d) of Regulation S-K.

 Response: The Co-Registrants
respectfully acknowledge the Staff's comment and advise the Staff that the Co-Registrants have amended the disclosure on pages xv,
10 and 109 of the Amended Registration Statement to include the requested information.

 Colombier Financial Analysis, page 101

 17. We
note your statement that Colombier did not prepare, and did not request that GrabAGun prepare projections in connection with the proposed
Business Combination. However, we also note that Colombier management used unaudited historical financial information provided by GrabAGun
to derive a "historical year over-year growth rate (‘1 YR BR Growth Rate') for GrabAGun of approximately 9.2%." Please revise
to include and describe the financial information and methodologies, assumptions, and limitations used to calculate the growth rate.
Refer to Item 1609 of Regulation S-K. Additionally, please disclose whether any financial information used to determine the 1 YR BR Growth
Rate changed after GrabAGun's financial statements were audited, and if any financial information did change, disclose whether the Colombier
Board was notified, if you re-calculated the growth rate, and if not, why not. If applicable, please also