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CORRESP
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 Odysseus Holdings Limited
 2nd Floor, 2 Hill Street,
 JE2 4UA St Helier Jersey,
 Channel Islands

 CoinShares International Limited
 2nd Floor, 2 Hill Street,
 JE2 4UA St Helier Jersey,
 Channel Islands

 March 12, 2026

 VIA EDGAR

 United States Securities and Exchange Commission
Division of Corporation Finance

 100 F Street NE
Washington, D.C. 20549

 Re:
 Acceleration Request for Odysseus Holdings Limited and CoinShares International Limited

 Registration Statement on Form F-4

 File No. 333-293885

 Requested Date:
 March 16, 2026

 Requested Time:
 4:00 p.m. Eastern Time

 Ladies and Gentlemen:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Odysseus Holdings Limited and CoinShares International Limited together hereby request that the
effective date of the above-captioned Registration Statement on Form F-4, as amended (the "Registration Statement"), be accelerated
to, and that the Registration Statement be declared effective at 4:00 p.m., Eastern Time, on March 16, 2026, or as soon as practicable
thereafter.

 Please contact Joel Rubinstein
(email: Joel.Rubinstein@whitecase.com or telephone: (212) 819-7642) of White & Case LLP with any questions and please notify him when
this request for acceleration has been granted.

 Very truly yours,

 Odysseus Holdings Limited

 CoinShares International Limited

 By:
 /s/ Jeri-Lea Brown

 By:
 /s/ Jean-Marie Mognetti

 Name:
 Jeri-Lea Brown

 Name:
 Jean-Marie Mognetti

 Title:
 Director

 Title:
 Chief Executive Officer

 cc:
 Joel Rubinstein, White & Case LLP