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Forefront Tech Holdings Acquisition Corp

c/o Appleby Global Services (Cayman) Limited

Suite 210, 2nd Floor, Windward III, Regatta Office Park, PO Box 500

Grand Cayman, Cayman Islands, KY1-1106

April 27, 2026

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    RE:
    Forefront Tech Holdings Acquisition Corp (the “Company”)

    Registration Statement on Form S-1

    (File No. 333- 293592) (the “Registration Statement”)

Ladies and Gentlemen:

Pursuant to Rule 461 under the
Securities Act of 1933, as amended, the registrant, Forefront Tech Holdings Acquisition Corp, hereby requests acceleration of effectiveness
of the above referenced Registration Statement on Form S-1 (File No. 333- 293592) so that it will become effective at 4:30 p.m. ET on
Wednesday, April 29, 2026, or as soon as practicable thereafter or at such other time as the Company or its outside counsel, Winston &
Strawn LLP, request by telephone that such Registration Statement be declared effective.

    Very truly yours,

    Forefront Tech Holdings Acquisition Corp

    By:
    /s/ Peter Bilitsch

    Name:
    Peter Bilitsch

    Title:
    Chief Executive Officer

    cc:
    Michael J. Blankenship, Winston & Strawn LLP

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April 27, 2026

VIA EDGAR

Division of Corporation Finance

Office of Real Estate & Construction

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Forefront Tech Holdings Acquisition Corp (the “Company”)

    Registration Statement on Form S-1

    File No. 333-293592

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”),
BTIG, LLC, as the representative of the underwriters of the offering, hereby joins the request of the Company that the effective date
of the above-captioned Registration Statement be accelerated so as to permit it to become effective at 4:30 p.m. ET on April 29, 2026,
or as soon as thereafter practicable.

Pursuant to Rule 460 of the General Rules and
Regulations of the Securities and Exchange Commission under the Securities Act, we, acting on behalf of the several underwriters, wish
to advise you that there will be distributed to each underwriter or dealer, who is reasonably anticipated to be invited 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.

We have complied and will continue to comply with
the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    /s/ Paul Wood

    Paul Wood

    Managing Director, Co-Head of SPAC Investment Banking

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 21, 2026

Peter Bilitsch
Chief Executive Officer
Forefront Tech Holdings Acquisition Corp
c/o Appleby Global Services (Cayman) Limited
71 Fort Street, PO Box 500
Grand Cayman, Cayman Islands, KY1-1106

 Re: Forefront Tech Holdings Acquisition Corp
 Draft Registration Statement on Form S-1
 Submitted December 12, 2025
 CIK No. 0002097986
Dear Peter Bilitsch:

 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 Stacie Gorman at 202-551-3585 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Michael J. Blankenship, Esq.
</TEXT>
</DOCUMENT>