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Correspondence 0001213900-26-039537 from Apogee Acquisition Corp (AACP, AACPU) (CIK 0002102123)

Apogee Acquisition Corp (AACP, AACPU) (CIK 0002102123)
Date: April 2, 2026 · CIK: 0002102123 · Accession: 0001213900-26-039537

AI Filing Summary & Sentiment

File numbers found in text: 333-294102

Date
April 2, 2026
Author
Managing Director
Form
CORRESP
Company
Apogee Acquisition Corp (AACP, AACPU) (CIK 0002102123)

Letter

ARC GROUP SECURITIES LLC

444 Madison Avenue, Suite 3301

New York, New York 10022

April 2, 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 April 6, 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 April 1, 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

Show Raw Text
CORRESP
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filename1.htm

ARC GROUP SECURITIES LLC

444 Madison Avenue, Suite 3301

New York, New York 10022

April 2, 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 April 6, 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 April 1, 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]