Correspondence 0001628280-26-033581 from Neptune Insurance Holdings Inc. (NP)
Neptune Insurance Holdings Inc.
Date: May 11, 2026 · CIK: 0002067129 · Accession: 0001628280-26-033581
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Document May 11, 2026 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Finance 100 F Street, N.E. Washington, D.C. 20549 Attn: Robert Arzonetti Re: Neptune Insurance Holdings Inc. Registration Statement on Form S-1 Submitted May 11, 2026 CIK No. 0002067129 Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned registrant, Neptune Insurance Holdings Inc., a Delaware corporation (the “ Registrant ”), hereby requests that the above-referenced Registration Statement on Form S-1 (the “ Registration Statement ”) be declared effective at 4:00 p.m., Eastern Time, on May 13, 2026, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Orrick, Herrington & Sutcliffe LLP, by calling Mark Mushkin at (212) 506-3507. The Registrant hereby authorizes Mark Mushkin of Orrick, Herrington & Sutcliffe LLP to orally modify or withdraw this request for acceleration. Thank you for your assistance in this matter. Kind regards, NEPTUNE INSURANCE HOLDINGS INC. By: /s/ Jim Steiner Name: Jim Steiner Title: Chief Financial Officer cc: Trevor Burgess, Neptune Insurance Holdings Inc. Jim Steiner, Neptune Insurance Holdings Inc. Matt Duffy, Neptune Insurance Holdings Inc. Michael J. Sullivan, Orrick, Herrington & Sutcliffe LLP Mark Mushkin, Orrick, Herrington & Sutcliffe LLP
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CORRESP 1 filename1.htm Document May 11, 2026 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Finance 100 F Street, N.E. Washington, D.C. 20549 Attn: Robert Arzonetti Re: Neptune Insurance Holdings Inc. Registration Statement on Form S-1 Submitted May 11, 2026 CIK No. 0002067129 Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned registrant, Neptune Insurance Holdings Inc., a Delaware corporation (the “ Registrant ”), hereby requests that the above-referenced Registration Statement on Form S-1 (the “ Registration Statement ”) be declared effective at 4:00 p.m., Eastern Time, on May 13, 2026, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Orrick, Herrington & Sutcliffe LLP, by calling Mark Mushkin at (212) 506-3507. The Registrant hereby authorizes Mark Mushkin of Orrick, Herrington & Sutcliffe LLP to orally modify or withdraw this request for acceleration. Thank you for your assistance in this matter. Kind regards, NEPTUNE INSURANCE HOLDINGS INC. By: /s/ Jim Steiner Name: Jim Steiner Title: Chief Financial Officer cc: Trevor Burgess, Neptune Insurance Holdings Inc. Jim Steiner, Neptune Insurance Holdings Inc. Matt Duffy, Neptune Insurance Holdings Inc. Michael J. Sullivan, Orrick, Herrington & Sutcliffe LLP Mark Mushkin, Orrick, Herrington & Sutcliffe LLP