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SEC Company Response from Churchill Capital Corp XI (CCXI) — Dec 15, 2025

Churchill Capital Corp XI
Date: Dec. 15, 2025 · CIK: 0002074973 · Accession: 0001213900-25-121580

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File numbers found in text: 333-291626

Date
December 15, 2025
Author
/s/ Michael Klein
Form
CORRESP
Company
Churchill Capital Corp XI

Letter

VIA EDGAR Division of Corporation Finance Office of Real Estate & Construction Attention: Stacie Gorman Re: Churchill Capital Corp XI Registration Statement on Form S-1 Filed November 18, 2025, as amended File No. 333-291626

Dear Ms. Gorman:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Churchill Capital Corp XI hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 4:30 p.m. ET on Tuesday, December 16, 2025, or as soon as thereafter practicable.

Very truly yours,
/s/ Michael Klein

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CORRESP
 1
 filename1.htm

 CHURCHILL CAPITAL CORP. XI

 640 Fifth Avenue, 14th Floor

 New York, NY 10019

 December 15, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, N.E.

 Washington, DC 20549

 Attention: Stacie Gorman

 Re:
 Churchill Capital Corp XI

 Registration Statement on Form S-1

 Filed November 18, 2025, as amended

 File No. 333-291626

 Dear Ms. Gorman:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Churchill Capital Corp XI hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effective at 4:30 p.m. ET on Tuesday, December 16, 2025, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Michael Klein

 Michael Klein

 Chief Executive Officer

 cc:
 Ellenoff Grossman & Schole LLP