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 CORRESP

 BridgeBio Oncology Therapeutics, Inc.
 256 E. Grand Avenue, Suite 104
 South San Francisco, CA 94080 September 8,
2025 VIA EDGAR Securities and Exchange
Commission Division of Corporation Finance Office of Life
Sciences 100 F Street, N.E. Washington, D.C. 20549

 Re:
 BridgeBio Oncology Therapeutics, Inc.
 Registration Statement on Form S-1
 File No. 333-289940
 Request for Acceleration Ladies and
Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), BridgeBio Oncology Therapeutics,
Inc. (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on
 Form S-1 (File No. 333-289940) (the “Registration Statement”), so that it may become effective at 4:01 pm Eastern time on
September 10, 2025, or as soon thereafter as practicable, unless we or our outside counsel, Goodwin Procter LLP, request by telephone that such Registration Statement be declared effective at some other time. In making this acceleration
request, the Company acknowledges that it is aware of its responsibilities under the Act. If you have any questions regarding this
request, please contact Maggie Wong, Esq. of Goodwin Procter LLP at (415) 733-6071.

 Very truly yours, BridgeBio
Oncology Therapeutics, Inc.

 By:

 /s/ Eli Wallace

 Name: Eli Wallace Title: Chief Executive
Officer
 cc: Maggie Wong, Goodwin Procter LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 3, 2025

Eli Wallace
Chief Executive Officer
BridgeBio Oncology Therapeutics, Inc.
256 E. Grand Avenue, Suite 104
South San Francisco, CA 94080

 Re: BridgeBio Oncology Therapeutics, Inc.
 Registration Statement on Form S-1
 Filed August 29, 2025
 File No. 333-289940
Dear Eli Wallace:

 This is to advise you that we have not reviewed and will not review your
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 Tim Buchmiller at 202-551-3635 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Maggie L. Wong, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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 Helix Acquisition Corp. II
 200 Clarendon Street, 52 nd Floor
 Boston, MA 02116
 TheRas, Inc.
 256 E. Grand Avenue, Suite 104
 South San Francisco, CA 94080

 July 9, 2025

 VIA EDGAR

 United States Securities and Exchange Commission
Division of Corporation Finance
Office of Life Sciences

 100 F Street NE
Washington, D.C. 20549

 Re:
 Acceleration Request for Helix Acquisition Corp. II and TheRas, Inc.

 Registration Statement on Form S-4

 File No. 333-288222

 Requested Date:
 July 10, 2025

 Requested Time:
 4:15 p.m. Eastern Time

 Ladies and Gentlemen:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Helix Acquisition Corp. II and TheRas, Inc. together hereby request that the effective date of
the above-captioned Registration Statement on Form S-4, as amended (the "Registration Statement"), be accelerated to, and
that the Registration Statement be declared effective at 4:15 p.m., Eastern Time, on July 10, 2025, or as soon as practicable thereafter.

 Please contact Joel Rubinstein (email: joel.rubinstein@whitecase.com
or telephone: (212) 819-7642) of White & Case LLP or Maggie L. Wong (email: mwong@goodwinlaw.com or telephone: (415) 733-6071) of
Goodwin Procter LLP with any questions and please notify one or more of them when this request for acceleration has been granted.

 Very truly yours,

 TheRas, Inc.

 Helix Acquisition
 Corp. II

 By:
 /s/ Eli Wallace

 By:
 /s/ Bihua
 Chen

 Name:
 Eli Wallace

 Name:
 Bihua Chen

 Title:
 Chief Executive Officer

 Title:
 Chief Executive Officer

 cc:
 Joel Rubinstein, White & Case LLP

 Maggie L. Wong., Goodwin Procter LLP

CORRESP
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 July 1, 2025

 VIA EDGAR
 United States Securities and Exchange Commission
 Division of Corporation Finance
 Office of Life Sciences
 100 F Street NE
 Washington, D.C. 20549

 Attn:

 Bonnie Baynes
 Angela Connell
 Tyler Howes
 Joshua Gorsky

 Re:

 Helix Acquisition Corp. II
 TheRas, Inc.
 Registration Statement on Form S-4
 Filed June 20, 2025
 File No. 333-288222

 Ladies and Gentlemen:

 On behalf of Helix Acquisition
Corp. II, a Cayman Islands exempted company (" Helix "), and TheRas, Inc. (d/b/a BridgeBio Oncology Therapeutics), a
Delaware corporation (" BBOT " and together with Helix, the " Co-Registrants "), we are writing to submit
the joint responses of Helix and BBOT to the comments of the staff of the Division of Corporation Finance of the United States Securities
and Exchange Commission (the " Staff ") with respect to the above referenced Registration Statement on Form S-4 submitted
on June 20, 2025 (the " Registration Statement "), contained in the Staff's letter dated June 27, 2025 (the " Comment
Letter ").

 The Co-Registrants have filed
via EDGAR Amendment No. 1 to the Registration Statement on Form S-4 (" Amendment No. 1 "), which reflects their joint
responses to the comments contained in the Comment Letter and certain updated information. For ease of reference, each comment contained
in the Comment Letter is printed below in bold and is followed by the response. All page references in the responses set forth below refer
to page numbers in Amendment No. 1. Capitalized terms used but not defined herein have the meanings set forth in Amendment No. 1.

 Registration Statement on Form S-4

 Dilution, page 236

 1.
 We note the revisions to your Dilution disclosure in response to prior comment one. Your revised NTBV calculation removes the adjustment to reflect the "conversion of Helix equity into equity of combined company" which was not the intent of our prior comment. Although the effects of the Business Combination itself should be excluded from the dilution disclosures, the lapse of redemption provisions after consummation of the Business Combination will result in such shares being reclassified to permanent equity. As such, it would appear that the value of such shares (after reflecting redemptions) should be included in your NTBV calculation. Further, your current NTBV per share calculation includes these shares in the denominator but excludes the value of such shares from the numerator. Please revise accordingly.

 Response : The Co-Registrants
have revised the disclosure on pages 236-237 of Amendment No. 1 in response to the Staff's comment.

 TheRas, Inc. - Notes to Unaudited Condensed
Financial Statements

 5. Commitments and Contingencies, page F-56

 2.
 We note your disclosure on page 300 of the April 2025 dispute over indexed milestone payments from the terminated UCSF license agreement and your disclosure on pages F-56 and F-82 that "[TheRas] is not currently involved in any legal actions that could have a material effect on the Company's financial position, results of operations, or liquidity." Please tell us your consideration of providing the disclosures required by ASC 450-20-50-3 through 50-5 as it relates to this potential loss contingency, including the amount or range of reasonably possible losses in excess of recorded amounts.

 Response : In response to the Staff's comment, the Co-Registrants respectfully
advise the Staff that, with respect to the UCSF matter, BBOT has determined that the conditions for a loss contingency have not been met
because BBOT believes that the likelihood that a loss will be incurred is remote. Accordingly, BBOT has determined that disclosure in
the financial statements of the matter involving the terminated UCSF license described on page 300 is not required under FASB ASC 450-20-50.
In reaching its determination, BBOT considered (i) that, to date, BBOT has only received a letter from UCSF asserting that a payment will
become due on an unspecified date in the future and no formal complaint has been filed, (ii) the advice of legal counsel and other advisors,
and (iii) BBOT's belief that it has meritorious and valid substantive defenses against the assertions made by UCSF. Based on its
review and in consideration of the impact on the financial statements, BBOT determined that neither an accrual for loss contingency nor
financial statement disclosure is required to be disclosed in the Registration Statement under FASB ASC 450-20-50.

 * * *

 Please do not hesitate to
contact Joel Rubinstein at (212) 819-7642 of White & Case LLP or Maggie L. Wong at (415) 733-6071 of Goodwin Procter LLP with any
questions or comments regarding this letter.

 Sincerely,

 /s/ White & Case LLP

 White & Case LLP

 cc:
 Bihua Chen, Helix Acquisition Corp. II

 Eli Wallace, TheRas, Inc.

June 27, 2025
Bihua Chen
Chief Executive Officer
Helix Acquisition Corp. II
200 Clarendon Street, 52nd Floor
Boston, MA 02116
Eli Wallace
Chief Executive Officer
TheRas, Inc.
256 E. Grand Avenue, Suite 104
South San Francisco, CA 94080
Re:Helix Acquisition Corp. II
TheRas, Inc.
Registration Statement on Form S-4
Filed June 20, 2025
File No. 333-288222
Dear Bihua Chen and Eli Wallace:
            We have reviewed your registration statement and have the following comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form S-4
Dilution, page 236
We note the revisions to your Dilution disclosure in response to prior comment
one. Your revised NTBV calculation removes the adjustment to reflect the
"conversion of Helix equity into equity of combined company" which was not the
intent of our prior comment. Although the effects of the Business Combination itself
should be excluded from the dilution disclosures, the lapse of redemption provisions 1.

June 27, 2025
Page 2
after consummation of the Business Combination will result in such shares being
reclassified to permanent equity. As such, it would appear that the value of such
shares (after reflecting redemptions) should be included in your NTBV
calculation. Further, your current NTBV per share calculation includes these shares in
the denominator but excludes the value of such shares from the numerator. Please
revise accordingly.
TheRas, Inc. - Notes to Unaudited Condensed Financial Statements
5. Commitments and Contingencies, page F-56
2.We note your disclosure on page 300 of the April 2025 dispute over indexed
milestone payments from the terminated UCSF license agreement and your disclosure
on pages F-56 and F-82 that " [TheRas] is not currently involved in any legal actions
that could have a material effect on the Company's financial position, results of
operations, or liquidity." Please tell us your consideration of providing the disclosures
required by ASC 450-20-50-3 through 50-5 as it relates to this potential loss
contingency, including the amount or range of reasonably possible losses in excess of
recorded amounts.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Bonnie Baynes at 202-551-4924 or Angela Connell at 202-551-3426 if
you have questions regarding comments on the financial statements and related
matters. Please contact Tyler Howes at 202-551-3370 or Joshua Gorsky at 202-551-7836
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Joel Rubinstein, Esq.
Maggie L. Wong, Esq.

CORRESP
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 June 20, 2025

 VIA EDGAR
 United States Securities and Exchange Commission
 Division of Corporation Finance
 Office of Life Sciences
 100 F Street NE
 Washington, D.C. 20549

 Attn:

 Bonnie Baynes
 Angela Connell
 Tyler Howes
 Joshua Gorsky

 Re:

 Helix Acquisition Corp. II
 TheRas, Inc.
 Amendment No. 1 to Draft Registration Statement on Form S-4
 Submitted May 30, 2025
 CIK No. 0001869105

 Ladies and Gentlemen:

 On behalf of Helix Acquisition
Corp. II, a Cayman Islands exempted company (" Helix "), and TheRas, Inc. (d/b/a BridgeBio Oncology Therapeutics), a
Delaware corporation (" BBOT " and together with Helix, the " Co-Registrants "), we are writing to submit
the joint responses of Helix and BBOT to the comments of the staff of the Division of Corporation Finance of the United States Securities
and Exchange Commission (the " Staff ") with respect to the above referenced Amendment No. 1 to Draft Registration Statement
on Form S-4 submitted on May 30, 2025 (the " Draft Registration Statement "), contained in the Staff's letter dated
June 11, 2025 (the " Comment Letter ").

 The Co-Registrants have filed
via EDGAR the Registration Statement on Form S-4 (the " Registration Statement "), which reflects their joint responses
to the comments contained in the Comment Letter and certain updated information. For ease of reference, each comment contained in the
Comment Letter is printed below in bold and is followed by the response. All page references in the responses set forth below refer to
page numbers in the Registration Statement. Capitalized terms used but not defined herein have the meanings set forth in the Registration
Statement.

 Amendment No. 1 to Draft Registration Statement
on Form S-4

 Dilution, page 236

 1.
 We note the revisions made to your tabular dilution disclosure in response to prior comment 10. Please revise your calculation of net tangible book value per share for each redemption scenario to exclude the effects of the Business Combination. In this regard, we note that you currently include an adjustment to the numerator to reflect BBOT net assets and an adjustment to the denominator to reflect conversion of BBOT shares into PubCo common stock. Item 1604(c) of Regulation S-K specifies that net tangible book value per share, as adjusted should exclude the de-SPAC transaction itself.

 Response : The Co-Registrants
have revised the disclosure on pages 236-237 of the Registration Statement in response to the Staff's comment.

 Information about BBOT

 BBOT's Business, page 260

 2.
 We note your response to prior comment 15. Please revise this section to disclose when you expect to complete enrollment for each of your clinical trials, so that investors can better understand your trial progress.

 Response : BBOT
submits to the Staff that it is not instructive to include information on the anticipated timelines for completing enrollment of its
ongoing Phase 1 open-label trials. Instead, BBOT is providing disclosure of when it intends to report data and will update its
disclosure to reflect planned regulatory interactions or initiation of subsequent trials as the development of each candidate
progresses. BBOT does not expect that enrollment in the trials will be linear and, importantly, these Phase 1 trials are open-label
trials. Open-label trials generate clinical data as patients are enrolled in the trial, and BBOT intends to report data regardless
of the number of patients enrolled as communicated to the public. The number of patients enrolled in the Phase 1 trials and the
timelines are not set given the nature of early stage oncology trials, and while BBOT currently has estimated enrollment targets,
BBOT may enroll fewer or additional patients before initiating subsequent trials, depending on the emerging safety profile,
pharmacokinetics, and anti-tumor activity data from these trials. The Co-Registrants have revised the disclosure on pages 260, 272,
and 277 of the Registration Statement to clarify the interim nature of the planned data announcements.

 * * *

 Please do not hesitate to
contact Joel Rubinstein at (212) 819-7642 of White & Case LLP or Maggie L. Wong at (415) 733-6071 of Goodwin Procter LLP with any
questions or comments regarding this letter.

 Sincerely,

 /s/ White & Case LLP

 White & Case LLP

 cc:
 Bihua Chen, Helix Acquisition Corp. II

 Eli Wallace, TheRas, Inc.

June 11, 2025
Bihua Chen
Chief Executive Officer
Helix Acquisition Corp. II
200 Clarendon Street, 52nd Floor
Boston, MA 02116
Eli Wallace
Chief Executive Officer
TheRas, Inc.
256 E. Grand Avenue, Suite 104
South San Francisco, CA 94080
Re:Helix Acquisition Corp. II
TheRas, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-4
Submitted May 30, 2025
CIK No. 0001869105
Dear Bihua Chen and Eli Wallace:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-4
Dilution, page 236
We note the revisions made to your tabular dilution disclosure in response to prior
comment 10. Please revise your calculation of net tangible book value per share for 1.

June 11, 2025
Page 2
each redemption scenario to exclude the effects of the Business Combination. In this
regard, we note that you currently include an adjustment to the numerator to reflect
BBOT net assets and an adjustment to the denominator to reflect conversion of BBOT
shares into PubCo common stock. Item 1604(c) of Regulation S-K specifies that net
tangible book value per share, as adjusted should exclude the de-SPAC transaction
itself.
Information about BBOT
BBOT's Business, page 260
2.We note your response to prior comment 15. Please revise this section to disclose
when you expect to complete enrollment for each of your clinical trials, so that
investors can better understand your trial progress.
            Please contact Bonnie Baynes at 202-551-4924 or Angela Connell at 202-551-3426 if
you have questions regarding comments on the financial statements and related
matters. Please contact Tyler Howes at 202-551-3370 or Joshua Gorsky at 202-551-7836
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Joel Rubinstein, Esq.
Maggie L. Wong, Esq.

May 12, 2025
Bihua Chen
Chief Executive Officer
Helix Acquisition Corp. II
200 Clarendon Street, 52nd Floor
Boston, MA 02116
Eli Wallace
Chief Executive Officer
TheRas, Inc.
256 E. Grand Avenue, Suite 104
South San Francisco, CA 94080
Re:Helix Acquisition Corp. II
TheRas, Inc.
Draft Registration Statement on Form S-4
Submitted April 15, 2025
CIK No. 0001869105
Dear Bihua Chen and Eli Wallace:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-4
Questions and Answers about the Business Combination
Q: How do the Sponsor, Cormorant and Helix's officers and directors intend to vote?, page
xxxvii
Please disclose if any consideration was received by the shareholders who have 1.

May 12, 2025
Page 2
agreed to vote in favor of the merger agreement.
Risk Factors
The third parties upon whom BBOT relies for the supply of the active pharmaceutical
ingredients..., page 81
2.Please revise this risk factor to name the sole source suppliers BBOT currently relies
upon and clarify if BBOT has entered into any supply agreements with them.
Background of the Business Combination, page 126
3.We note your disclosure on page 127 that the "board of directors of Company A and
Helix were unable to reach mutually agreeable terms, and Helix's offer to enter into
the letter of intent expired without further pursuit by Helix." Please revise your
disclosure to provide further details about the discussions that Helix had with
Company A, including, but not limited to, the reasons why the parties were unable to
reach mutually agreeable terms.
4.We note your disclosure that in "late 2024, in light of clinical data emerging at an
accelerated timeline, Helix['s] management team started considering BBOT as a
potential target candidate[.]" Please revise your disclosure to specify the clinical data
that emerged at this time that led Helix's management team to consider BBOT as a
potential target.
5.We note your disclosure that "Helix derived the pre-transaction equity value proposed
by considering the clinical progress that had been made since the BBOT Series B
Financing and the relative valuations for similar clinical stage companies
contemplating initial public offerings in 2025." Please revise your disclosure to
identify the "similar clinical stage companies" referenced here.
The Transaction Committee's and Helix Board's Reasons for the Approval of the Business
Combination, page 134
6.We note your disclosure that the "Transaction Committee and Helix Board believe
that BBOT has multiple clinical assets with anticipated value inflection points over
the next 9 to 18 months[.]" Please revise your disclosure to specify what the
Committee and the Board believe the "anticipated value inflection points" will be.
Opinion of Lincoln International LLC, page 141
7.Disclose any instructions received by Lincoln International LLC from Helix or the
Sponsor, and any limitations imposed by Helix or the Sponsor, on the scope of the
activities conducted by Lincoln in connection with the fairness opinion. Refer to Item
1607(b)(6) of Regulation S-K.
Selected Public Companies Analysis, page 145
Please revise your table on page 145 to identify the material metrics applicable to each
public company selected. In addition, please revise to discuss how Lincoln considered
the differing stages of operations when comparing BBOT to the selected
companies. For example, explain if any adjustments to the final enterprise value were
made based on the fact that BBOT does not yet have any products approved for 8.

May 12, 2025
Page 3
commercial sale.
9.Please clarify whether any of the selected public companies that Lincoln evaluated
became public through a business combination with a special purpose acquisition
company. Similarly, please clarify whether any of the selected M&A transactions
or the selected capital raise transactions that Lincoln evaluated involved a special
purpose acquisition company. If not, please explain the reasons why such
comparisons were not made.
Dilution, page 235
10.Please revise your dilution disclosure to clearly disclose how your historical net
tangible book value (NTBV) was calculated. Please also separately quantify the
components of both the numerator and denominator of your NTBV per share for each
redemption scenario. In this regard, your tabular disclosure should show:
•your historical net book value;
•the nature and amounts of each source of dilution used to determine net tangible
book value, as adjusted;
•the number of shares used to determine net tangible book value per share, as
adjusted; and
•any adjustments to the number of shares used to determine the per share
component of net tangible book value per share, as adjusted.
Refer to Item 1604(c) of Regulation S-K.
11.In both your 75% and 100% of maximum redemption scenarios, you assume that the
Minimum Cash Condition will not be met but that BBOT will waive this condition.
We note your disclosure elsewhere, however, that it is your understanding that BBOT
does not intend to waive the Minimum Cash Condition and accordingly, you may seek
to obtain additional financing to meet the Minimum Cash Condition. To the extent
that in these scenarios you anticipate obtaining additional financing in order to
proceed with the business combination, the effects of this additional financing should
be included in your dilution disclosure. Conversely, if you do not anticipate obtaining
sufficient additional financing to meet the Minimum Cash Condition, your redemption
scenarios should be adjusted such that your maximum redemption scenario represents
the maximum amount of redemptions that could occur while also meeting the
Minimum Cash Condition without additional financing. Please revise accordingly
throughout your filing whenever redemption scenarios are provided.
Information about BBOT
BBOT's Business, page 257
12.We note your disclosure here and throughout your Prospectus stating, among other
things, that your PI3K α inhibitors enabled “potent” inhibition and showed "strong
activity" against the ON-Form of KRAS G12C. Please revise these and similar
statements throughout your prospectus to eliminate conclusions or predictions that
your product candidates are effective, as determinations of efficacy are solely within
the authority of the FDA.

May 12, 2025
Page 4
Overview of BBO-8520 Program
Preclinical, page 260
13.Please clarify if your preclinical testing that resulted in BBO8520
comparing "favorably" to sotorasib and adagrasib in ERK phosphorylation inhibition
and 3D viability assays was the result of head-to-head testing. To the extent it was
not, please remove this comparison.
Clinical, page 262
14.Please remove the statement on page 264 claiming that BBO-8520's safety profile
appeared "favorable" as safety determinations are within the sole discretion of the
FDA and comparable foreign regulators.
15.Please revise to disclose the number of patients you have enrolled and intend to enroll
in your ONKORAS-101 and BREAKER-101 Phase 1 studies.
Overview of BBO-11818 Program
Preclinical, page 271
16.Please revise to briefly discuss the material aspects of your trial design for your
planned Phase 1 KONQUER-101 trial. Your revisions should include the number of
patients you plan to enroll, current enrollment numbers and planned endpoints.
17.We note your disclosure that the discovery of BBO-11818 was facilitated, in part, by
"artificial intelligence learnings from [y]our KRAS G12C inhibitor program[.]" Please
provide further details about the "artificial intelligence learnings" referenced here.
License and Cooperative Research and Development Agreements, page 278
18.Please revise to disclose the aggregate amounts paid to date under each licensing
agreement discussed in this section.
19.We note that several of the agreements discussed in this section require BBOT to pay
a "minimum annual royalty" and a "mid double-digit percentage of certain non-
royalty consideration received under a sublicense to a third party." For each of these
agreements, please disclose the amount that could be owed under the minimum annual
royalty provision and specify the range for the non-royalty consideration within ten
percentage points.
LLNS Cooperative Research and Development Agreement, page 278
20.We note your disclosure that this agreement will expire on June 22, 2025 unless the
parties mutually agree to extend the term. Please revise your disclosure to clarify if
the parties have had any discussions to mutually extend the term of this agreement.
Management of PubCo Following the Business Combination, page 313
21.Please disclose if you intend to enter into new employment agreements with each of
BBOT's named executive officers following the business combination or if PubCo
intends to assume the offer letter agreements BBOT previously entered into with
management. If PubCo intends to assume the offer letter agreements, please file each
agreement as an exhibit to this registration statement. Refer to Item 601 of Regulation
S-K for guidance.

May 12, 2025
Page 5
General
22.We note that you intend to file the form of preliminary proxy card as Exhibit 99.1.
Please note that the form of proxy card should be filed as an appendix rather than as
an exhibit to the registration statement. Refer to the Note to paragraph (a)(3) of the
Exchange Act Rule 14a-4.
            Please contact Bonnie Baynes at 202-551-4924 or Angela Connell at 202-551-3426 if
you have questions regarding comments on the financial statements and related
matters. Please contact Tyler Howes at 202-551-3370 or Joshua Gorsky at 202-551-7836
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Joel Rubinstein, Esq.
Maggie L. Wong, Esq.

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Helix Acquisition Corp. II

c/o Cormorant Asset Management, LP

200 Clarendon Street, 52nd Floor

Boston, MA 02116

February 7, 2024

VIA EDGAR

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Attn:
    Paul Cline

    Isaac Esquivel

    Ronald E. Alper

    Pam Howell

    Re:
    Helix Acquisition Corp. II

    Registration Statement on Form S-1

    Filed January 18, 2024, as amended

    File No. 333-276591

Ladies and Gentlemen:

Pursuant to Rule 461 of the
rules and regulations promulgated under the Securities Act of 1933, as amended, Helix Acquisition Corp. II respectfully requests that
the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m. Washington
D.C. time on February 8, 2024, or as soon thereafter as practicable.

Please call Joel L. Rubinstein
of White & Case LLP at (212) 819-7642 to provide notice of the effectiveness of the Registration Statement.

[Signature Page Follows]

    Very truly yours,

    Helix Acquisition Corp. II

    By:
    /s/ Bihua Chen

    Name:
    Bihua Chen

    Title:
    Chief Executive Officer and Chairperson

cc: Joel L. Rubinstein, White & Case LLP

CORRESP
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February 7, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ronald (Ron) E. Alper

    Re:
    Helix Acquisition Corp. II
 Registration Statement on Form S-1
 File No. 333-276591

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act
of 1933, as amended (the “Act”), the undersigned hereby joins in the request of Helix Acquisition Corp. II that the effective
date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m. ET on February
8, 2024, or as soon as thereafter practicable.

Pursuant to Rule 460 of the General Rules and
Regulations under the Act, the undersigned wishes to advise you that there will be distributed to each underwriter or dealer, who is reasonably
anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advises that it has complied and
will continue to comply with the requirements of Rule 15c2-8 under the Securities and Exchange Act of 1934, as amended.

[signature page follows]

Very truly yours,

Leerink Partners LLC

  /s/ Stuart Nayman

  Name:
  Stuart Nayman

  Title:
  Managing Director, Senior Legal Counsel

CORRESP
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February 6, 2024

  VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance,

Office of Real Estate & Construction

100 F Street, NE

Washington, D.C. 20549

 Attn: Paul Cline

Isaac Esquivel

Ronald E. Alper

Pam Howell

 Re: Helix Acquisition Corp. II

Amendment No. 1 to Registration Statement on
Form S-1

Filed February 2, 2024

File No. 333-276591

Ladies and Gentlemen:

On behalf of our client, Helix Acquisition Corp.
II, a Cayman Islands exempted company (the “Company”), we are writing to submit the Company’s response
to the comment of the staff of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Staff”)
with respect to the above-referenced Amendment No. 1 to Registration Statement on Form S-1 filed on February 2, 2024 (“Amendment
No. 1”), contained in the Staff’s letter dated February 6, 2024 (the “Comment Letter”).

The Company has filed via EDGAR Amendment No.
2 to the Registration Statement (“Amendment No. 2”), which reflects the Company’s response to the comment
received from the Staff and certain updated information. For ease of reference, the comment contained in the Comment Letter is printed
below in bold and is followed by the Company’s response. All page references in the response set forth below refer to page numbers
in Amendment No. 2 as filed.

Amendment No. 1 to Registration Statement on Form S-1 filed February
2, 2024

Risk Factors, page 32

 1. We note your investment company risk factors beginning on page 41. Please disclose that if you are found to be operating as an
unregistered investment company, you may be required to change your operations, wind down your operations, or register as an investment
company under the Investment Company Act. Also include disclosure with respect to the consequences to investors if you are required to
wind down your operations as a result of this status, such as the losses of the investment opportunity in a target company, and any price
appreciation in the combined company. Please confirm that if your facts and circumstances change over time, you will update your disclosure
to reflect how those changes impact the risk that you may be considered to be operating as an unregistered investment company.

Response: The Company has revised the disclosure on page 42 of Amendment
No. 2 to address the Staff’s comment. The Company hereby confirms that if, in the future, it determines that the facts and circumstances
material to the Company’s potential status as an investment company have changed, it will update the applicable disclosure in future
filings with the SEC to the extent required to reflect how those changes impact the risk that the Company may be considered to be operating
as an unregistered investment company.

* * *

Please do not hesitate to contact Joel L. Rubinstein
at (212) 819-7642 of White & Case LLP with any questions or comments regarding this letter.

    Sincerely,

    /s/ White & Case LLP

    White & Case LLP

cc: Bihua Chen, Helix Acquisition Corp. II

United States securities and exchange commission logo
February 6, 2024
Bihua Chen
Chief Executive Officer
Helix Acquisition Corp. II
200 Clarendon Street, 52nd Floor
Boston, MA 02116
Re:Helix Acquisition Corp. II
Amendment No. 1 to Registration Statement on Form S-1
Filed February 2, 2024
File No. 333-276591
Dear Bihua Chen:
            We have reviewed your amended registration statement and have the following comment.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1 filed February 2, 2024
Risk Factors, page 32
1.We note your investment company risk factors beginning on page 41. Please disclose that
if you are found to be operating as an unregistered investment company, you may be
required to change your operations, wind down your operations, or register as an
investment company under the Investment Company Act. Also include disclosure with
respect to the consequences to investors if you are required to wind down your operations
as a result of this status, such as the losses of the investment opportunity in a target
company, and any price appreciation in the combined company.  Please confirm that if
your facts and circumstances change over time, you will update your disclosure to reflect
how those changes impact the risk that you may be considered to be operating as an
unregistered investment company.

 FirstName LastNameBihua Chen
 Comapany NameHelix Acquisition Corp. II
 February 6, 2024 Page 2
 FirstName LastName
Bihua Chen
Helix Acquisition Corp. II
February 6, 2024
Page 2
            Please contact Paul Cline at 202-551-3851 or Isaac Esquivel at 202-551-3395 if you have
questions regarding the financial statements and related matters. Please contact Ronald (Ron) E.
Alper at 202-551-3329 or Pam Howell at 202-551-3357 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Joel Rubinstein

CORRESP
1
filename1.htm

February
2, 2024

    VIA EDGAR

                            United States Securities and Exchange Commission

Division of Corporation Finance,

Office of Real Estate & Construction

100 F Street, NE

Washington, D.C. 20549

  Attn:
  Paul Cline

Isaac
Esquivel

Ronald
E. Alper

Pam
Howell

Re: Helix
                                            Acquisition Corp. II

Registration
Statement on Form S-1

Filed
January 18, 2024

File
No. 333-276591

Ladies
and Gentlemen:

On
behalf of our client, Helix Acquisition Corp. II, a Cayman Islands exempted company (the “Company”), we are
writing to submit the Company’s response to the comment of the staff of the Division of Corporation Finance of the United States
Securities and Exchange Commission (the “Staff”) with respect to the above-referenced registration statement
on Form S-1 filed on January 18, 2024 (the “Registration Statement”), contained in the Staff’s letter
dated January 23, 2024 (the “Comment Letter”).

The
Company has filed via EDGAR Amendment No. 1 to the Registration Statement (“Amendment No. 1”), which reflects
the Company’s response to the comment received from the Staff and certain updated information. For ease of reference, the comment
contained in the Comment Letter is printed below in bold and is followed by the Company’s response. All page references in the
response set forth below refer to page numbers in Amendment No.1 as filed.

Registration
Statement on Form S-1 filed January 18, 2024

We
may issue our shares to investors in connection with our initial business combination… page 47

 1. We
                                            partially reissue prior comment 1. Please disclose that the agreements are intended to ensure
                                            a return on investment to the investor in return for funds facilitating the sponsor’s
                                            completion of the business combination or providing sufficient liquidity. Additionally, please
                                            also disclose that these arrangements result in costs particular to the de-SPAC process that
                                            would not be anticipated in a traditional IPO. Lastly, please provide additional disclosure
                                            of the resultant risks to investors.

Response:
The Company has revised the disclosure on page 47 of Amendment No.1 to address the Staff’s comment.

*
* *

Please
do not hesitate to contact Joel L. Rubinstein at (212) 819-7642 of White & Case LLP with any questions or comments regarding this
letter.

    Sincerely,

    /s/ White & Case LLP

    White & Case LLP

    cc:
    Bihua Chen, Helix Acquisition Corp. II

United States securities and exchange commission logo
January 23, 2024
Bihua Chen
Chief Executive Officer
Helix Acquisition Corp. II
200 Clarendon Street, 52nd Floor
Boston, MA 02116
Re:Helix Acquisition Corp. II
Registration Statement on Form S-1
Filed January 18, 2024
File No. 333-276591
Dear Bihua Chen:
            We have reviewed your registration statement and have the following comment.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our January 10, 2024 letter.
Registration Statement on Form S-1 filed January 18, 2024
We may issue our shares to investors in connection with our initial business combination ....,
page 47
1.We partially reissue prior comment 1. Please disclose that the agreements are intended to
ensure a return on investment to the investor in return for funds facilitating the sponsor’s
completion of the business combination or providing sufficient liquidity. Additionally,
please also disclose that these arrangements result in costs particular to the de-SPAC
process that would not be anticipated in a traditional IPO. Lastly, please provide
additional disclosure of the resultant risks to investors.

 FirstName LastNameBihua Chen
 Comapany NameHelix Acquisition Corp. II
 January 23, 2024 Page 2
 FirstName LastName
Bihua Chen
Helix Acquisition Corp. II
January 23, 2024
Page 2
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Paul Cline at 202-551-3851 or Isaac Esquivel at 202-551-3395 if you have
questions regarding the financial statements and related matters. Please contact Ronald (Ron) E.
Alper at 202-551-3329 or Pam Howell at 202-551-3357 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Joel Rubinstein

CORRESP
1
filename1.htm

January 18,
2024

                         VIA EDGAR

                         United States Securities and Exchange Commission

Division of Corporation Finance,

Office of Real Estate & Construction

100 F Street, NE

Washington, D.C. 20549

Attn:  Paul Cline

    Isaac Esquivel

    Ronald E. Alper

    Pam Howell

Re:  Helix Acquisition Corp. II

    Draft Registration Statement on Form S-1

    Submitted December 20, 2023

    CIK No. 0001869105

Ladies and Gentlemen:

On behalf of our client, Helix Acquisition Corp.
II, a Cayman Islands exempted company (the “Company”), we are writing to submit the Company’s responses
to the comments of the staff of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Staff”)
with respect to the above-referenced draft registration statement submitted on December 20, 2023 (the “Draft Registration
Statement”), contained in the Staff’s letter dated January 10, 2024 (the “Comment Letter”).

The Company has filed via EDGAR its Registration
Statement on Form S-1 (“Registration Statement”), which reflects the Company’s responses to the comments
received from the Staff and certain updated information. For ease of reference, each comment contained in the Comment Letter is printed
below in bold and is followed by the Company’s response. All page references in the responses set forth below refer to page numbers
in Registration Statement as filed.

Draft Registration Statement on Form S-1 submitted December 20,
2023

We may issue our shares to investors in connection with our initial
business combination, page 47

 1. We note your disclosure here and your references to PIPE transactions elsewhere. Please clearly disclose their impact to you and
investors. To the extent you may utilize PIPE transactions, disclose that the agreements are intended to ensure a return on investment
to the investor in return for funds facilitating the sponsor’s completion of the business combination or providing sufficient liquidity.
Additionally, please also disclose that these arrangements result in costs particular to the de-SPAC process that would not be anticipated
in a traditional IPO. Lastly, please clarify here and throughout the prospectus whether the PIPE transactions may occur at a price below
the IPO price of $10 per share and if so, the resultant risks.

Response: The Company has revised the disclosure on page 47 of the
Registration Statement to address the Staff’s comment.

The new 1% U.S. federal excise tax on stock buybacks could be
imposed, page 69

 2. We note that this risk factor describes the potential material
                                            effect on your shareholders of the stock buyback excise
                                            tax enacted as part of the Inflation Reduction Act of August 2022. Please also describe the
                                            risks of the excise tax applying to redemptions in connection with:

 ● liquidations
                                            that are not implemented to fall within the meaning of “complete liquidation”
                                            in Section 331 of the Internal Revenue Code;

 ● extensions,
                                            depending on the timing of the extension relative to when the SPAC completes a de-SPAC or
                                            liquidates; and

 ● de-SPACs,
                                            depending on the structure of the de-SPAC transaction.

Response:
The Company acknowledges the Staff’s comment and has revised the risk factor regarding the excise tax on page 69 of the Registration
Statement to discuss the risks of the excise tax applying to redemptions in connection with liquidations, extensions and business combinations.

Our
amended and restated memorandum and articles of association provide that the courts of the

Cayman
Islands will be the exclusive, page 72

 3. Please
                                            reconcile the disclosure in this risk factor that “the forum selection provision in
                                            our amended and restated memorandum and articles of association will not apply to actions
                                            or suits brought to enforce any liability or duty created by the Securities Act, Exchange
                                            Act or any claim for which the federal district courts of the United States are, as a matter
                                            of the laws of the United States, the sole and exclusive forum for determination of such
                                            a claim” with the disclosure on page 139 that “our amended and restated memorandum
                                            and articles of association also provide that, unless we consent in writing to the selection
                                            of an alternative forum, to the fullest extent permitted by law, the federal district courts
                                            of the United States will be the exclusive forum for the resolution of any complaint asserting
                                            a cause of action arising under the federal securities laws of the United States, including
                                            those arising under the Securities Act or Exchange Act.”

Response:
The Company has revised the disclosure on page 139 of the Registration Statement to address the Staff’s comment.

Permitted
Purchases of Our Securities, page 97

 4. We
                                            note that unlike traditional SPACs, your offering does not include warrants. Please explain
                                            the references to the potential purchase of public warrants in this section or remove.

Response:
The Company has removed the references to the potential purchase of public warrants starting on page 97 of the Registration Statement
as such disclosure is not applicable.

    2

Directors’
Fiduciary Duties and Conflicts of Interest, page 118

 5. Please
                                            expand your disclosure in this section to highlight the financial conflicts of interest of
                                            your sponsor, officers, directors, advisors and/or your or their affiliates, as the case
                                            may be. For example, highlight, to the extent applicable, conflicts arising from ownership
                                            of the founder shares and private placement shares, including that:

 ● because
                                            of the low price they paid for the founder shares, your sponsor and your officers and directors
                                            may make a substantial profit even if the company selects an acquisition target that subsequently
                                            declines in value and is unprofitable for public investors;

 ● if
                                            you do not consummate a business combination within the time required, the founder shares,
                                            private placement units, and their underlying securities will expire worthless; and

 ● highlight
                                            whether employment or consulting agreements negotiated with a target business in connection
                                            with a business combination, or other agreements providing for compensation following an
                                            initial business combination, may cause your officers and directors to have a conflict of
                                            interest.

Response:
The Company has revised and expanded the disclosure on page 121 of the Registration Statement to address the Staff’s comment.

Principal
Shareholders, page 123

 6. Please
                                            revise to include Bihua Chen in the beneficial ownership table and include the shares owned
                                            through Helix Holdings II LLC, your sponsor, as reflected in footnote three to the table.
                                            Please also revise the amount held by officers and directors as a group.

Response:
The Company has revised the beneficial ownership table on page 123 of the Registration Statement to address the Staff’s comment.

Signatures,
page II-4

 7. Please
                                            include the signatures of the majority of the board of directors. See Instruction 1 to Signatures
                                            to Form S-1.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure starting on page 113 of the Registration Statement
to clarify that Bihua Chen is the only member of the board of directors of the Company at the time of filing of the Registration Statement.

*
* *

    3

Please
do not hesitate to contact Joel L. Rubinstein at (212) 819-7642 of White & Case LLP with any questions or comments regarding this
letter.

  Sincerely,

  /s/ White & Case LLP

  White
& Case LLP

cc:  Bihua
Chen, Helix Acquisition Corp. II

4

United States securities and exchange commission logo
January 10, 2024
Bihua Chen
Chief Executive Officer
Helix Acquisition Corp. II
200 Clarendon Street, 52nd Floor
Boston, MA 02116
Re:Helix Acquisition Corp. II
Draft Registration Statement on Form S-1
Submitted December 20, 2023
CIK No. 0001869105
Dear Bihua Chen:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Draft Registration Statement on Form S-1 submitted December 20, 2023
We may issue our shares to investors in connection with our initial business combination...., page
47
1.We note your disclosure here and your references to PIPE transactions elsewhere. Please
clearly disclose their impact to you and investors. To the extent you may utilize PIPE
transactions, disclose that the agreements are intended to ensure a return on investment to
the investor in return for funds facilitating the sponsor’s completion of the business
combination or providing sufficient liquidity. Additionally, please also disclose that these
arrangements result in costs particular to the de-SPAC process that would not be
anticipated in a traditional IPO. Lastly, please clarify here and throughout the prospectus
whether the PIPE transactions may occur at a price below the IPO price of $10 per share
and if so, the resultant risks.

 FirstName LastNameBihua Chen
 Comapany NameHelix Acquisition Corp. II
 January 10, 2024 Page 2
 FirstName LastName
Bihua Chen
Helix Acquisition Corp. II
January 10, 2024
Page 2
The new 1% U.S. federal excise tax on stock buybacks could be imposed...., page 69
2.We note that this risk factor describes the potential material effect on your shareholders of
the stock buyback excise tax enacted as part of the Inflation Reduction Act of August
2022. Please also describe the risks of the excise tax applying to redemptions in
connection with:
•liquidations that are not implemented to fall within the meaning of “complete
liquidation” in Section 331 of the Internal Revenue Code;
•extensions, depending on the timing of the extension relative to when the SPAC
completes a de-SPAC or liquidates; and
•de-SPACs, depending on the structure of the de-SPAC transaction.
Our amended and restated memorandum and articles of association provide that the courts of the
Cayman Islands will be the exclusive...., page 72
3.Please reconcile the disclosure in this risk factor that "the forum selection provision in our
amended and restated memorandum and articles of association will not apply to actions or
suits brought to enforce any liability or duty created by the Securities Act, Exchange Act
or any claim for which the federal district courts of the United States are, as a matter of
the laws of the United States, the sole and exclusive forum for determination of such a
claim" with the disclosure on page 139 that "our amended and restated memorandum and
articles of association also provide that, unless we consent in writing to the selection of an
alternative forum, to the fullest extent permitted by law, the federal district courts of the
United States will be the exclusive forum for the resolution of any complaint asserting a
cause of action arising under the federal securities laws of the United States, including
those arising under the Securities Act or Exchange Act."
Permitted Purchases of Our Securities, page 97
4.We note that unlike traditional SPACs, your offering does not include warrants.  Please
explain the references to the potential purchase of public warrants in this section or
remove.
Directors' Fiduciary Duties and Conflicts of Interest, page 118
5.Please expand your disclosure in this section to highlight the financial conflicts of interest
of your sponsor, officers, directors, advisors and/or your or their affiliates, as the case may
be. For example, highlight, to the extent applicable, conflicts arising from ownership of
the founder shares and private placement shares, including that:
•because of the low price they paid for the founder shares, your sponsor and
your officers and directors may make a substantial profit even if the company selects
an acquisition target that subsequently declines in value and is unprofitable for public
investors;
•if you do not consummate a business combination within the time required, the
founder shares, private placement units, and their underlying securities will expire

 FirstName LastNameBihua Chen
 Comapany NameHelix Acquisition Corp. II
 January 10, 2024 Page 3
 FirstName LastName
Bihua Chen
Helix Acquisition Corp. II
January 10, 2024
Page 3
worthless; and
•highlight whether employment or consulting agreements negotiated with a target
business in connection with a business combination, or other agreements providing
for compensation following an initial business combination, may cause your officers
and directors to have a conflict of interest.
Principal Shareholders, page 123
6.Please revise to include Bihua Chen in the beneficial ownership table and include the
shares owned through Helix Holdings II LLC, your sponsor, as reflected in footnote three
to the table.  Please also revise the amount held by officers and directors as a group.
Signatures, page II-4
7.Please include the signatures of the majority of the board of directors.  See Instruction 1 to
Signatures to Form S-1.
            Please contact Paul Cline at 202-551-3851 or Isaac Esquivel at 202-551-3395 if you have
questions regarding the financial statements and related matters. Please contact Ronald (Ron) E.
Alper at 202-551-3329 or Pam Howell at 202-551-3357 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Joel Rubinstein