SEC Company Response from Churchill Capital Corp XI (CCXI) — Dec 15, 2025
Churchill Capital Corp XI
Date: Dec. 15, 2025 · CIK: 0002074973 · Accession: 0001213900-25-121584
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File numbers found in text: 333-291626
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CORRESP 1 filename1.htm Citigroup Global Markets Inc. 388 Greenwich Street New York, New York 10013 December 15, 2025 VIA EDGAR Stacie Gorman United States Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, N.E. Washington, D.C. 20549 Re: Churchill Capital Corp XI Registration Statement on Form S-1 Filed November 18, 2025, as amended File No. 333-291626 Dear Ladies and Gentlemen: Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Act"), the undersigned, for itself, hereby joins in the request of Churchill Capital Corp XI that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:30 p.m. Eastern time on Tuesday, December 16, 2025, or as soon thereafter as practicable. Pursuant to Rule 460 of the General Rules and Regulations under the Act, the undersigned advises that approximately 200 copies of the Preliminary Prospectus dated December 10, 2025 are expected to be distributed to prospective underwriters and dealers, institutional investors, retail investors and others. The undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. * * * [ Signature Page Follows ] Very truly yours, Citigroup Global Markets Inc. By: /s/ Pavan Bellur Name: Pavan Bellur Title: Managing Director As the Underwriter