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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: 0001213900-25-121584

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File numbers found in text: 333-291626

Date
December 15, 2025
Author
Managing Director
Form
CORRESP
Company
Churchill Capital Corp XI

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 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.

Show Raw Text
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