Correspondence 0001213900-26-033605 from Apogee Acquisition Corp (AACP, AACPU) (CIK 0002102123)
Apogee Acquisition Corp (AACP, AACPU) (CIK 0002102123)
Date: March 24, 2026 · CIK: 0002102123 · Accession: 0001213900-26-033605
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File numbers found in text: 333-294102
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CORRESP
1
filename1.htm
ARC
GROUP SECURITIES LLC
444
Madison Avenue, Suite 3301
New
York, New York 10022
March
24, 2026
VIA
EMAIL & EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
100
F Street, N.E.
Washington,
D.C. 20549
Re:
Apogee Acquisition Corp (the “Company”)
Registration
Statement on Form S-1 (Registration No. 333-294102)
Ladies
and Gentlemen:
In
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”),
the undersigned hereby joins the request of the Company that the effectiveness for the above-captioned Registration Statement on Form
S-1 (the “Registration Statement”) filed under the Securities Act be accelerated by the Securities and Exchange Commission
to 4:00 p.m. Eastern Time, on March 26, 2026, or as soon thereafter as practicable, or at such other time as the Company or its outside
counsel, Greenberg Traurig P.A., request by telephone that such Registration Statement be declared effective.
Pursuant
to Rule 460 under the Securities Act, please be advised that we will distribute to each underwriter, dealer or institution who is reasonably
anticipated to participate in the offering as many copies of the preliminary prospectus dated March 23, 2026 (the “Preliminary
Prospectus”) as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.
We,
the undersigned, as representative of the several underwriters, have complied and will comply with the requirements of Rule 15c2-8 under
the Securities Exchange Act of 1934, as amended.
[Signature
Page Follows]
Very truly yours,
ARC GROUP SECURITIES LLC
By:
/s/
Roger Salazar, Jr.
Name:
Roger
Salazar, Jr.
Title:
Managing
Director
[Signature
Page – Acceleration Request]