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September 10, 2025

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, DC 20549

Attn: Jeff Kauten

    Re:

    Elauwit Connection, Inc.

    Registration Statement on Form S-1

    Filed August 29, 2025

    File No. 333-289964

Dear Mr. Kauten:

On behalf of Elauwit Connection, Inc. (the “Company”),
we are responding to the comment of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities
and Exchange Commission set forth in the Staff’s letter, dated September 3, 2025, providing the Staff’s comment with respect
to the Company’s Registration Statement on Form S-1.

For the convenience of the Staff, the Staff’s
comment is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise, references in
this letter to “we,” “us” and “our” refer to the Company.

Registration Statement on Form S-1

Prospectus Summary

Our Company, page 1

 1. Revise your disclosures to clarify how you define pipeline and the specific stages of the sales cycle
that have been completed for these opportunities. Clarify if you have signed agreements with customers for any of these opportunities
and, if so, quantify the associated revenue. Please also clarify the basis for your expectation that these opportunities will convert
to sales, the expected timeline to conversion, and the specific factors that have a reasonable likelihood of preventing conversion to
sales.

Response: The Company
respectfully acknowledges the Staff’s comment and intends to revise its disclosure relating to its pipeline by revising the second
major bullet point on page 1 to read as follows, with new or revised disclosure indicated in bold italics:

“The number of opportunities
that we estimate can begin generating revenue for us within the next 24 months (our “pipeline”) is
rapidly growing due to our longstanding relationships and expanding customer base. From both existing and new customer
relationships, we are currently tracking over 400 opportunities in our Managed Service pipeline representing an estimated $110
million of potential network construction revenue and an estimated $23 million in annual recurring revenue, if we were able
to successfully complete all of these opportunities. We have also identified approximately 265,000 units in our near-term
Network-as-a-Service pipeline, based on ongoing, active discussions with approximately 10 property ownership groups,
which we estimate could represent approximately $150 million in annual recurring revenue, based on an estimated
monthly fee of approximately $45 per unit. We do not have any contracts with customers for opportunities in our pipeline. See
 “— Pipeline” below for more detail about our pipeline.”

    1600 BAUSCH & LOMB PLACE ROCHESTER, NY 14604-2711 PHONE: 585.232.6500 FAX: 585.232.2152

    rochester, ny • buffalo, ny • albany, ny • corning, ny • new york, ny

U.S. Securities and Exchange Commission

Division of Corporation Finance

September 10, 2025

Page 2

The new subsection “Pipeline” will appear immediately before
 “Corporate History and Structure” in the Prospectus Summary section and read as follows:

Managed Service

As of September 4, 2025, our Managed Service
pipeline consists of 400 opportunities to provide service to about 110,000 units, representing in total an estimated $110 million of potential
network construction revenue and an estimated $23 million in annual recurring revenue. The majority of our Managed Service pipeline consists
of requests for proposal (“RFPs”) with existing and new customers, with the remaining smaller portion consisting of direct
sales outside of an RFP process.

An opportunity is first added to our Managed
Service pipeline when one of our representatives has an introductory call about the opportunity with a third party. Currently, about 30,000
units are in this early stage of the pipeline, representing the potential for approximately $30 million in network construction revenue
and about $7 million in annual recurring revenue. The second stage of the pipeline is what we consider “near-term” opportunities,
when (i) a design has been requested for a project; (ii) a design proposal has been delivered for a project; (iii) the project is being
negotiated between the project ownership group or its subcontractors and us; or (iv) when the project has been verbally awarded to us
and we are finalizing a written contract for the project. Currently, about 80,000 units are in the second stage of the pipeline, representing
the potential for approximately $80 million in network construction revenue and about $16 million in annual recurring revenue. We do not
have any contracts with customers for opportunities in the first or second stage of our Managed Service pipeline. After a contract for
a project is signed, the project is no longer in the pipeline and is instead considered part of our backlog. See “Management’s
Discussion and Analysis of Financial Condition and Results of Operations — Contracted Units and Backlog” for more information
about our backlog.

We are a relatively new business with limited
long-term win-loss data on project submissions and do not have a reasonable estimated win rate for Managed Service projects in the early,
first stage of our pipeline. However, based on our historical experience and management’s estimates and experience in this industry,
we estimate our win rate on Managed Service second stage pipeline projects in which we respond to an RFP for a new customer or new property
ownership group is approximately 25%. We estimate our win rate on RFPs with existing customers or direct sales to property ownership groups
with whom we have an existing relationship is higher than 25%. Because Managed Service projects are subject to the timeline of a new construction
project, which is outside of our control, we cannot predict an exact timeline for generating revenue for each opportunity in our pipeline;
however, based on our historical experience we would expect to begin to generate revenue for most opportunities in the second stage of
our Managed Service pipeline in the next 18 months. Managed Service pipeline opportunities could be prevented from converting into sales
if we are not able to remain competitive in developing our proposals or executing on our backlog, or if there is a slowdown in new construction
for multifamily projects.

U.S. Securities and Exchange Commission

Division of Corporation Finance

September 10, 2025

Page 3

Network-as-a-Service

As of September 4, 2025, our
Network-as-a-Service pipeline consists of approximately 265,000 identified units, based on ongoing, active discussions with
approximately 10 property ownership groups with whom we have an existing relationship. If all of these units were converted into
contracted units, we estimate we could recognize approximately $150 million in annual recurring revenue, based on an estimated
monthly fee of approximately $45 per unit. Currently, all of our Network-as-a-Service pipeline is in the earliest stage of our
pipeline, which we expect to follow the stages of the Managed Service pipeline described above. These opportunities entered our
Network-as-a-Service pipeline when our management team began negotiating with the property ownership groups and the ownership group
expressed interest in Network-as-a-Service. We will need additional capital to begin Network-as-a-Service buildouts, and until we
are able to access additional capital, the opportunities in the first stage of our Network-as-a-Service pipeline will not advance in
the pipeline. We do not have any contracts with customers for projects in our Network-as-a-Service pipeline that require payment if
the customer cancels the contract before the network is installed. The potential revenue under any contract that would require
payment would appear in our backlog.

Because Network-as-a-Service is a new business
model, we have only limited data on our ability to convert opportunities from our pipeline into revenue. Our Network-as-a-Service pipeline
is based on our management’s estimate of our opportunities in our total addressable market. Our total addressable market, of multi-family
properties with at least 100 units, consists of about 12 million units nationwide. Our current Network-as-a-Service pipeline is roughly
2.2% of that total addressable market. Assuming we are able to access additional capital, we believe we could begin generating revenue
from Network-as-a-Service sales to the identified property ownership groups within 12 months. Our ability to convert these pipeline opportunities
into sales is based on management’s estimates and experience in this industry. Network-as-a-Service pipeline opportunities could
be prevented from converting into sales if we are unable to access adequate capital to deploy for Network-as-a-Service buildouts or to
develop our direct sales and marketing team for Network-as-a-Service sales, if our potential customers prefer a business model other than
Network-as-a-Service, or if our proposed service is viewed unfavorably compared to our competitors.

The Company also intends to make conforming changes
to the disclosure on page 30 under the heading “Executive Summary” in the section entitled “Business.” Similarly,
the Company will move the fourth paragraph on page 34 under the heading “Our Market Opportunity” to a new subsection titled
 “Pipeline” which will be substantially similar to the “Pipeline” section above and make conforming changes to
the existing paragraph.

The Company intends to revise the second last
sentence of the risk factor titled “If we are unable to consistently win competitive RFP processes, become a preferred or sole supplier
for new-build projects, begin to increase our gross margins with newer customer relationships, or capitalize on the opportunities in our
pipeline, our financial condition, results of operations and business may be adversely impacted” as follows, with new disclosure
indicated in bold italics:

We cannot
provide any assurance that we will consistently win every RFP process we enter, become a preferred or sole supplier for new-build projects,
execute on our backlog, begin to increase our gross margins with newer customer relationships, access capital to deploy
for Network-as-a-Service buildouts or to develop our sales and marketing teams, or capitalize on the opportunities in our pipeline.

U.S. Securities and Exchange Commission

Division of Corporation Finance

September 10, 2025

Page 4

If you have any further questions or comments,
or if you require any additional information, please do not hesitate to contact the Company’s Chief Financial Officer, Sean Arnette,
by email at sarnette@elauwit.com or telephone at (980) 705-3160, or the undersigned by email at mrhoda@hselaw.com or telephone at (585)
231-1267.

    Very truly yours,

    /s/ Margaret K. Rhoda

    Margaret K. Rhoda

    direct dial: 585.231.1267

    email: Mrhoda@hselaw.com

  cc:
  Alexander R. McClean, Esq

  Barry Rubens, Chief Executive Officer