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CORRESP
 1
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 CORRESP

 VIA EDGAR SUBMISSION
 August 5, 2025 United States Securities and Exchange
Commission Division of Corporation Finance Office of
Manufacturing 100 F Street, N.E. Washington, D.C. 20549

 Attention:

 Jeff Gordon Melissa Gilmore
 Bradley Ecker Asia Timmons-Pierce

 Re:

 Firefly Aerospace Inc.

 Registration Statement on Form S-1

 Registration File No. 333-288646
 Ladies and Gentlemen:
 In accordance with Rule 461 under the Securities Act of 1933, Firefly Aerospace Inc. (the “Company”) hereby requests that the
effective date for the Registration Statement referred to above (the “Registration Statement”) be accelerated so that it will become effective at 4:00 p.m., Eastern Time, on August 6, 2025, or as soon thereafter as is practicable.
 Please contact Kevin M. Frank at (312) 862-3373 or, in his absence, Ashley Sinclair at (312) 862-3928, both of Kirkland & Ellis LLP, the Company’s legal counsel, when the Registration Statement has been declared effective or if you have any other questions or concerns regarding this matter.
 Thank you in advance for your assistance.
 * * * * *

 Very truly yours,

 FIREFLY AEROSPACE INC.

 By:

 /s/ David Wheeler

 Name:

 David Wheeler

 Title:

 General Counsel, Secretary and Senior Vice President
 Firefly Aerospace Inc. | www.fireflyspace.com
 1320 Arrow Point Drive #109 | Cedar Park, TX 78613 | T 512.893.5570

 cc:
 Jason Kim, Chief Executive Officer, Firefly Aerospace Inc.
 Robert M. Hayward, P.C., Kirkland & Ellis LLP
 Kevin M. Frank, Kirkland & Ellis LLP
 Ashley Sinclair, Kirkland & Ellis LLP
 Michael Kaplan, Davis Polk & Wardwell LLP
 Stephen Byeff, Davis Polk & Wardwell LLP

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 Goldman Sachs & Co. LLC
 200 West Street New York, New York 10282
 J.P. Morgan Securities LLC 383 Madison Avenue
 New York, New York 10179 Jefferies LLC
 520 Madison Avenue New York, New York 10022
 Wells Fargo Securities, LLC 500 West 33rd Street 14th Floor
 New York, New York 10001 August 5, 2025
 VIA EDGAR United States Securities and Exchange Commission
 Division of Corporate Finance Office of Technology
 100 F Street, NE Washington, D.C. 20549
 Attention: Bradley Ecker and Asia Timmons-Pierce

 Re:
 Firefly Aerospace Inc.
 Registration Statement on Form S-1
 Filed July 11, 2025, as amended
 File No. 333-288646
 Ladies and Gentlemen: In accordance with Rule 461 under the
Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of Firefly Aerospace Inc. (the “Company”) 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. New York City time on Wednesday, August 6, 2025 or as soon thereafter as practicable, or at such other time thereafter as the Company or its outside counsel,
Kirkland & Ellis LLP, may request by telephone to the staff of the U.S. Securities and Exchange Commission. Pursuant to Rule 460 under the Act,
we, as representatives of the several underwriters, wish to advise you that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of securities, as many copies of the preliminary
prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus. We, the undersigned, as representatives of the several underwriters, will comply with the requirements of Rule
 15c2-8 under the Securities Exchange Act of 1934, as amended. * * *

 Very truly yours,
 Goldman Sachs & Co. LLC J.P. Morgan Securities LLC
 Jefferies LLC Wells Fargo Securities, LLC
 as representatives of the several underwriters

 Goldman Sachs & Co. LLC

 By:

 /s/ Ryan Cunn

 Name: Ryan Cunn

 Title: Managing Director

 J.P. Morgan Securities LLC

 By:

 /s/ Arun Kumarathas

 Name: Arun Kumarathas

 Title: Vice President

 Jefferies LLC

 By:

 /s/ Scott Skidmore

 Name: Scott Skidmore

 Title: Managing Director

 Wells Fargo Securities, LLC

 By:

 /s/ Jill Ford

 Name: Jill Ford

 Title: Co-Head of Equity Capital Markets

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 Kevin M. Frank

 333 Wolf Point Plaza
 Chicago, IL 60654 United
States

 To Call Writer Directly:

 Facsimile:

 +1 312 862 3373

 +1 312 862 2000

 +1 312 862 2200

 kevin.frank@kirkland.com

 www.kirkland.com

 July 28, 2025
 VIA EDGAR SUBMISSION United States Securities and
Exchange Commission Division of Corporation Finance Office
of Manufacturing 100 F Street, N.E. Washington, D.C. 20549

 Attention:
 Jeff Gordon
 Melissa Gilmore
 Bradley Ecker
 Asia Timmons-Pierce

 Re:
 Firefly Aerospace Inc.
 Registration Statement on Form S-1
 Submitted July 11, 2025
 File No. 333-288646
 Ladies and Gentlemen: Pursuant to the
requirements of the Securities Act of 1933, as amended, and Regulation S-T thereunder, Firefly Aerospace Inc., a Delaware corporation (the “Company”), has today filed with the Securities and Exchange
Commission (the “SEC”) Amendment No. 1 to the Registration Statement on Form S-1 (the “Revised Registration Statement”).
 On behalf of the Company, we are writing to respond to the comment raised in the letter to the Company, dated July 23, 2025, from the
staff of the SEC (the “Staff”) relating to the Registration Statement on Form S-1 previously filed with the Staff on July 11, 2025. The Company’s response below corresponds to the caption
and number of that comment (which are reproduced below in bold and italics). Where applicable, we have also referenced in the Company’s response set forth below the appropriate page numbers of the updated prospectus contained in the Revised
Registration Statement (the “Prospectus”) that address the Staff’s comment. In addition to addressing the comment raised by the Staff in its letter, the Company has revised the Revised Registration Statement to update certain other
disclosures. Capitalized terms used in this letter but not otherwise defined have the meanings assigned to them in the Prospectus. Austin Bay Area
Beijing Boston Brussels Chicago Dallas Frankfurt Hong Kong Houston London Los Angeles Miami Munich New York Paris Philadelphia Riyadh Salt Lake City Shanghai Washington, D.C.

 Securities and Exchange Commission
 July 28, 2025 Page
 2

 Form S-1 filed July 11, 2025
 General

 1.
 We note your multi launch agreement with Lockheed Martin that includes up to 25 missions over the next
five years. We note Alpha’s launch experienced a mishap during your April 2025 launch and the FAA grounded Alpha until further notice. Please update your disclosures to disclose this launch failure, impact of the launch failure on your business
and any updates on the FAA investigation. Please update your summary, risk factor and any other relevant section of your prospectus.
 RESPONSE: In response
to the Staff’s comment, the Company has revised its disclosure throughout the Revised Registration Statement to include additional detail on the launch failure of Alpha, the impact of the launch failure on its business and certain other updates
on the FAA investigation, including, but not limited to, the bolded language added on page 14 of the Revised Registration Statement below:
 We may encounter a range of challenges associated with launch failures, including potential regulatory delays, which could
affect our operations and business outcomes. For example, on April 29, 2025 an anomaly occurred during our Alpha mission that launched from Vandenberg Space Force Base in California. As a result, the Federal Aviation Administration
(“FAA”) is requiring us to conduct a mishap investigation before we can conduct further launches, which investigation is ongoing. A return to flight for Alpha is dependent upon FAA approval following their determining that any system,
process, or procedure related to the mishap does not affect public safety. Until such approval is provided, we will not be able to conduct further Alpha launches, which will adversely affect our revenues. While we believe the FAA will provide its
approval, there is no guarantee that we will receive such approval from the FAA in a timely manner, if at all, and any delay in such approval could have a material adverse effect on our business, financial condition, and results of operations. See
“Risk Factors—Risks Related to Our Business—We have in the past and may in the future experience delayed launches, launch failures, failure of our launch vehicles, landers, or orbital vehicles to reach their planned orbital locations,
significant increases in the costs related to launches of launch vehicles, landers, or orbital vehicles, and insufficient capacity available from third-party providers of launch services with whom we partner. Any such issue could result in the loss
of our launch vehicles, landers, or orbital vehicles or cause significant delays in their deployment, which could harm our business, financial condition, and results of operations” and “Risk Factors—

 Securities and Exchange Commission
 July 28, 2025 Page
 3

Risks Related to Our Business—Any inability to operate Alpha at our anticipated launch rate could adversely impact our business, financial condition, and results of operations.”
 We hope that the foregoing has been responsive to the Staff’s comment. Should you have any questions relating to any of the
foregoing, please feel free to contact Kevin M. Frank at (312) 862-3373 or, in his absence, Ashley Sinclair at (312) 862-3928.

 Sincerely,

 /s/ Kevin M. Frank

 Kevin M. Frank

 cc:
 Jason Kim
 Chief Executive Officer, Firefly Aerospace Inc.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 23, 2025

Jason Kim
Chief Executive Officer
Firefly Aerospace Inc.
1320 Arrow Point Drive #109
Cedar Park, TX 78613

 Re: Firefly Aerospace Inc.
 Registration Statement on Form S-1
 Filed July 11, 2025
 File No. 333-288646
Dear Jason Kim:

 We have reviewed your registration statement and have the following
comment(s).

 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.

Form S-1 filed July 11, 2025
General

1. We note your multi launch agreement with Lockheed Martin that includes
up to 25
 missions over the next five years. We note Alpha s launch experienced
a mishap
 during your April 2025 launch and the FAA grounded Alpha until further
notice.
 Please update your disclosures to disclose this launch failure, impact
of the launch
 failure on your business and any updates on the FAA investigation.
Please update
 your summary, risk factor and any other relevant section of your
prospectus.
 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
 July 23, 2025
Page 2

time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Jeff Gordon at 202-551-3866 or Melissa Gilmore at
202-551-3777 if
you have questions regarding comments on the financial statements and related
matters. Please contact Bradley Ecker at 202-551-4985 or Asia Timmons-Pierce at
202-551-
3754 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
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<DOCUMENT>
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<TEXT>
 May 13, 2025

Jason Kim
Chief Executive Officer
Firefly Aerospace Inc.
1320 Arrow Point Drive #109
Cedar Park, TX 78613

 Re: Firefly Aerospace Inc.
 Draft Registration Statement on Form S-1
 Submitted April 16, 2025
 CIK No. 0001860160
Dear Jason Kim:

 We have reviewed your draft registration statement and have the following
comment(s).

 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 filed April 16, 2025
Prospectus Summary, page 1

1. Please balance the disclosure in your summary by prominently disclosing
your level
 of indebtedness, history of losses, and other challenges you face.
Business, page 97

2. We note your disclosure that the MLV is in final development in
partnership with
 Northrop Grumman and that you expect the first launch to take place from
Virginia s
 Mid-Atlantic Regional Spaceport on Wallops Island. Please revise to
disclose
 anticipated timing of your MLV launch and/or first delivery.
 May 13, 2025
Page 2

Intellectual Property, page 109

3. Please disclose the duration and effect of all patents, trademarks,
licenses, franchises,
 and concessions held. Refer to Item 101(c) of Regulation S-K.
Regulatory, page 109

4. Please revise your disclosure in this section to describe the material
effects that
 compliance with government regulations may have upon your capital
expenditures,
 earnings and competitive position. Please also address international
regulations
 related to your business.
Index to Consolidated Financial Statements, page F-1

5. Please note the updating requirements of Rule 8-08 of Regulation S-X.
Note 18. Segment and Geographical Information, page F-52

6. You disclose on page F-52 that you did not recognize revenue outside of
the United
 States as of December 31, 2024; however, you disclose on page 55 that a
substantial
 portion of your revenue is generated from customers outside of the
United States.
 Please address this apparent discrepancy and ensure future disclosures
are revised as
 appropriate.
General

7. Please provide us supplemental copies of all written communications, as
defined in
 Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your
 behalf, have presented or expect to present to potential investors in
reliance on Section
 5(d) of the Securities Act, whether or not you retained or intend to
retain copies of
 these communications. Please contact legal staff associated with the
review of this
 filing to discuss how to submit the materials, if any, to us for review.
8. We note that one customer accounted for 58% of your revenues in 2024.
Please
 disclose terms of your material agreements file all material agreements
as exhibits to
 your registration statement. If you believe you are not substantially
dependent on any
 such agreement, please explain why. Refer to Item 601(b)(10) of
Regulation S-K.
 Please contact Jeff Gordon at 202-551-3866 or Melissa Gilmore at
202-551-3777 if
you have questions regarding comments on the financial statements and related
matters. Please contact Bradley Ecker at 202-551-4985 or Asia Timmons-Pierce at
202-551-
3754 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
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