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 July 8, 2025

Daniel B. Wolfe
Chief Executive Officer
Yukon New Parent, Inc.
c/o 180 Degree Capital Corp.
7 N. Willow Street, Suite 4B
Montclair, NJ 07042

 Re: Yukon New Parent, Inc.
 Amendment No. 2 to the Registration Statement on Form S-4
 Response dated July 3, 2025
 File No. 333-286043
Dear Daniel B. Wolfe:

 We have reviewed your correspondence dated July 3, 2025 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. Unless
we note
otherwise, any references to prior comments are to comments in our July 1, 2025
letter.

Response dated July 3, 2025
Summary, page 11

1. We note multiple references to 180 Degree Capital Corp. being an
investment
 company registered under the 1940 Act with the SEC, and the plan to
deregister.
 Refer to comment 5 of our June 3, 2025 letter. Please revise here and
where
 appropriate to summarize the timeline for transitioning between
regulatory regimes. In
 this regard, it appears that dispositions may be required in order to
fall within the
 40% test. Please revise to clarify.
 July 8, 2025
Page 2
General

2. We note your response to prior comment 1 regarding the 26% return on
equity
 disclosed in the January 2025 presentation about the merger and assuming
 the "hypothetical $10 million capital contribution from Mount Logan."
Please revise
 as requested in prior comment 1 or advise us why you believe the 26% ROE
is not
 inconsistent with the references on pages 20 and 121 of the registration
statement to
 an "Implied Breakeven Return on Equity." Additionally, please revise
Background of
 the Merger and where appropriate to address the hypothetical $10 million
capital
 contribution from Mount Logan or advise us why you believe that element
of the
 investor presentation is not material to investors.
3. Please revise Management of New Mount Logan on page 197 to identify the
directors
 currently omitted in brackets. In this regard, we note the Form 425
dated June 27,
 2025, which refers to a "Director Election Special Meeting." Please
revise Summary
 and where appropriate to address the Director Election Special Meeting
and related
 shareholder demand. Revise to explain the assumed timing of delivering
proxy
 materials and conducting meetings. With a view to clarifying disclosure,
advise us
 why the director election is not being conducted at the special meeting
for the merger.

 Please contact Lory Empie at 202-551-3714 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Robert Arzonetti at 202-551-8819 or James Lopez at 202-551-3536 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: John Mahon, Esq.
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