SecProbe.io

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KPET Ultra Paceline Corporation

5109 S. Broadband Lane

Sioux Falls, SD 57108

(605) 338-0233

March 26, 2026

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549-3561

Attention: Pam Howell

Re: KPET
Ultra Paceline Corporation

  Form S-1 Registration Statement

  Filed March 5, 2026, as amended

  File No. 333-294067

Dear Ms. Howell:

KPET Ultra Paceline Corporation (the “Company”)
hereby requests that the effective date of the Company’s Registration Statement on Form S-1, as amended (File No. 333-294067), be
accelerated under Rule 461 under the Securities Act of 1933, as amended, so that it will be declared effective at 4:00 pm (Eastern time)
on March 30, 2026, or as soon thereafter as possible.

We request that we be notified of such effectiveness
by a telephone call to Stancell Haigwood of Vinson & Elkins L.L.P. at (212) 237-0035 and that such effectiveness also be confirmed
in writing.

[Remainder of page intentionally left blank.]

    Sincerely,

    KPET Ultra Paceline Corporation

    By:
    /s/ Roger Edward Tamraz

    Name:
    Roger Edward Tamraz

    Title:
    Chief Financial Officer

  cc:

  Ropes & Gray LLP

  Paul D. Tropp

  Christopher J. Capuzzi

  Vinson & Elkins L.L.P.

  Sarah K. Morgan

  Stancell Haigwood

[Signature Page to Company
Acceleration Request]

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VIA EDGAR

Deutsche Bank Securities Inc.

1 Columbus Circle

New York, New York 10019

March 26, 2026

Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

Re: KPET Ultra Paceline Corporation

  Registration Statement on Form S-1

  Registration File No. 333-294067

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended (the “Act”), we, as representative of the several underwriters, hereby join in the request of KPET
Ultra Paceline Corporation (the “Company”) for acceleration of the effective date of the above-named Registration Statement
on Form S-1, as amended, so that it becomes effective at 4:00 PM, Eastern Time, on March 30, 2026,
or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Vinson & Elkins LLP, request by
telephone that such Registration Statement be declared effective.

Pursuant to Rule 460 under the Act, we, as representative
of the several underwriters, wish to advise you that we intend to distribute to each underwriter, dealer or institution who is reasonably
anticipated to participate in the offering as many copies of the Preliminary Prospectus included in the above-named Registration Statement,
as amended, as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

We, the undersigned, as representative of the several
underwriters, will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

    Very truly yours,

    By:
    Deutsche Bank Securities Inc.

    By:
    /s/ Eric Hackel

    Name:
    Eric Hackel

    Title:
    Managing Director

    By:
    /s/ Jeffrey H. Bunzel

    Name:
    Jeffrey H. Bunzel

    Title:
    Managing Director

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 13, 2026

Karl Peterson
Chief Executive Officer
Paceline Solutions Corp
5109 S. Broadband Lane
Sioux Falls, SD 57108

 Re: Paceline Solutions Corp
 Draft Registration Statement on Form S-1
 Submitted November 26, 2025
 CIK No. 0002095297
Dear Karl Peterson:

 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 Pam Howell at 202-551-3357 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
</TEXT>
</DOCUMENT>