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SEC Company Response from Vine Hill Capital Investment Corp. II (VHCP) — Dec 15, 2025

Vine Hill Capital Investment Corp. II
Date: Dec. 15, 2025 · CIK: 0002086264 · Accession: 0001213900-25-121764

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File numbers found in text: 333-291793

Date
December 15, 2025
Author
/s/ Nicholas Petruska
Form
CORRESP
Company
Vine Hill Capital Investment Corp. II

Letter

Re: Vine Hill Capital Investment Corp. II Registration Statement on Form S-1, as amended File No. 333-291793

Vine Hill Capital Investment Corp. II 500 E Broward Blvd., Suite 900

Fort Lauderdale, FL 33394

December 15, 2025

VIA EDGAR

Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Vine Hill Capital Investment Corp. II, a Cayman Islands exempted company (the " Company "), hereby requests acceleration of the effective date of the above referenced Registration Statement to 4:00 p.m., Eastern Time, on Wednesday, December 17, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Paul Hastings LLP, request by telephone that such Registration Statement be declared effective.

Please contact Jonathan Ko of Paul Hastings LLP, counsel to the Company, at (213) 683-6188, as soon as the registration statement has been declared effective, or if you have any other questions or concerns regarding this matter.

Sincerely,
/s/ Nicholas Petruska

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CORRESP
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 filename1.htm

 Vine Hill Capital Investment Corp. II
500 E Broward Blvd., Suite 900

 Fort Lauderdale, FL 33394

 December 15, 2025

 VIA EDGAR

 Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

 Re: Vine Hill Capital Investment Corp. II
Registration Statement on Form S-1, as amended
File No. 333-291793

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act of
1933, as amended, Vine Hill Capital Investment Corp. II, a Cayman Islands exempted company (the " Company "), hereby
requests acceleration of the effective date of the above referenced Registration Statement to 4:00 p.m., Eastern Time, on Wednesday, December 17, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Paul Hastings LLP, request
by telephone that such Registration Statement be declared effective.

 Please contact Jonathan Ko of Paul Hastings LLP,
counsel to the Company, at (213) 683-6188, as soon as the registration statement has been declared effective, or if you have any other
questions or concerns regarding this matter.

 Sincerely,

 /s/ Nicholas Petruska

 Nicholas Petruska

 Chief Executive Officer