SecProbe.io

CORRESP
1
filename1.htm

Apogee Acquisition Corp

2106 House Ave Suite 375

Cheyenne, Wyoming 82001

April 2, 2026

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

RE:  Apogee Acquisition Corp (the “Company”)

	Registration Statement on Form S-1

	(File No. 333-294102) (the “Registration Statement”)

Gentlemen:

The Company hereby requests,
pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the Registration Statement
so that such Registration Statement will become effective as of 4:00 p.m. on April 6, 2026, or as soon thereafter as practicable.

[Signature page follows]

    Very truly yours,

    Apogee Acquisition Corp

    By:
    /s/ Jeffrey Smith

    Name:
    Jeffrey Smith

    Title:
    Chief Executive Officer

CORRESP
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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]

CORRESP
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Apogee Acquisition Corp

2106 House Ave Suite 375

Cheyenne, Wyoming 82001

March 26, 2026

VIA EDGAR

United States Securities and Exchange

Commission Division of Corporation Finance

100 F Street, NE

Washington, D.C.

20549

    RE:
    Apogee Acquisition Corp (the “Company”)

    Registration Statement on Form S-1

    (File No. 333-294102) (the “Registration Statement”)

Gentlemen:

Reference is made to the letter submitted as correspondence via EDGAR
on March 24, 2026 in which the Company requested the acceleration of the above-referenced Registration Statement.

The Company is no longer requesting that such Registration Statement
be declared effective at this time and we hereby formally withdraw our request for acceleration of the effective date.

[Signature page follows]

    Very truly yours,

    APOGEE ACQUISITION CORP

    By:
    /s/ Jeffrey Smith

    Name:
    Jeffrey Smith

    Title:
    Chief Executive Officer

    cc:
    Tricia Branker, Esq., Greenberg Traurig, P.A.

CORRESP
1
filename1.htm

March 26, 2026

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3561

Re: Apogee Acquisition Corp (the “Company”)

Withdrawal of Acceleration Request - Registration Statement on Form S-1 (File No. 333-294102)

Ladies and Gentlemen:

Reference is made to our letter, filed
as correspondence via EDGAR on March 24, 2026, in which we, as representative of the several underwriters of Apogee Acquisition Corp’s
proposed public offering of units, joined the Company's request for acceleration of the effective date of the above-referenced Registration
Statement for Thursday, March 26, 2026, at 4:00 p.m. Eastern Time. The Company is no longer requesting that such Registration Statement
be declared effective at this time and we hereby formally withdraw our request for acceleration of the effective date.

    Very truly yours,

    ARC GROUP SECURITIES LLC

    As representative of the several underwriters

    By:
    /s/ Roger Salazar, Jr.

    Name:
    Roger Salazar, Jr.

    Title:
    Managing Director

CORRESP
1
filename1.htm

Apogee Acquisition Corp

2106 House Ave Suite 375

Cheyenne, Wyoming 82001

March 24, 2026

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

RE:  Apogee Acquisition
                                            Corp (the “Company”)

    Registration Statement on Form S-1

    (File No. 333-294102) (the “Registration
                                            Statement”)

Gentlemen:

The Company hereby requests,
pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the Registration Statement
so that such Registration Statement will become effective as of 4:00 p.m. on March 26, 2026, or as soon thereafter as practicable.

[Signature page follows]

    Very truly yours,

    Apogee Acquisition Corp

    By:
    /s/ Jeffrey Smith

    Name:
    Jeffrey Smith

    Title:
    Chief Executive Officer

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]

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 26, 2026

Jeffrey Smith
Chief Executive Officer
Apogee Acquisition Corp
2106 House Ave Suite 375
Cheyenne, WY 82001

 Re: Apogee Acquisition Corp
 Draft Registration Statement on Form S-1
 Submitted December 23, 2025
 CIK No. 0002102123
Dear Jeffrey Smith:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement and
nonpublic draft
submissions at least 15 days prior to any road show as that term is defined in
Rule 433(h)(4) or,
in the absence of a road show, at least 15 days prior to the requested
effective date of the
registration statement. Please refer to Rules 460 and 461 regarding requests
for acceleration. We
remind you that the company and its management are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by the
staff.

 Please contact Pearlyne Paulemon at 202-551-8714 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Tricia Branker
</TEXT>
</DOCUMENT>