SecProbe.io

CORRESP
 1
 filename1.htm

 UBS Securities LLC

 1285 Avenue of the Americas

 New York, NY 10019

 July 15, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, DC 20549

 Attention: Benjamin Holt

 Re:

 Pyrophyte Acquisition Corp. II
 Registration Statement
 on Form S-1
 Initially filed June
 27, 2025, as amended
 File No. 333- 288391

 Dear Mr. Holt,

 Pursuant to Rule 461 under the
Securities Act of 1933, as amended (the "Act"), the undersigned, as representative of the underwriters in the offering subject
to the registration statement referred to above, hereby joins in the request of Pyrophyte 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 Wednesday, July
16, 2025, or as soon thereafter as 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]

 Sincerely,

 UBS Securities LLC

 By:
 /s/ Adam Kerbis

 Name: Adam Kerbis

 Title: Executive Director

 By:
 /s/ Alex Cahail

 Name: Alex Cahail

 Title: Director

 [Signature Page to Underwriters' Acceleration
Request]

CORRESP
 1
 filename1.htm

 Pyrophyte Acquisition Corp. II

 3262 Westheimer Road, Suite 706

 Houston, Texas 77098

 July 15, 2025

 VIA EDGAR

 Benjamin Holt

 Division of Corporation Finance

 Office of Real Estate & Construction

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, DC 20549-3233

 Re:
 Pyrophyte Acquisition Corp. II

 Registration Statement on Form S-1

 Filed June 27, 2025, as amended

 File No. 333-288391

 Dear Mr. Holt:

 Pursuant to Rule 461 of the
rules and regulations promulgated under the Securities Act of 1933, as amended, Pyrophyte 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. Eastern
Time on July 16, 2025, or as soon thereafter as practicable.

 Please call Elliott Smith
of Perkins Coie LLP at (212) 261-6847 to provide notice of the effectiveness of the Registration Statement.

 [ Signature Page Follows ]

 Very truly yours,

 By:
 /s/ Sten Gustafson

 Name:
 Sten Gustafson

 Title:
 Chief Financial Officer

 cc: Elliott Smith, Perkins Coie LLP

 [ Signature Page to Acceleration Request ]

CORRESP
 1
 filename1.htm

 Pyrophyte Acquisition Corp. II

 3262 Westheimer Road, Suite 706

 Houston, Texas 77098

 July 14, 2025

 VIA EDGAR

 Benjamin Holt

 Division of Corporation Finance

 Office of Real Estate & Construction

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549-3233

 Re:
 Pyrophyte Acquisition Corp. II

 Registration Statement on Form S-1

 Filed June 27, 2025, as amended

 File No. 333-288391

 Dear Mr. Holt:

 Pyrophyte Acquisition Corp.
II hereby withdraws its prior acceleration request, dated July 11, 2025, with respect to its Registration Statement on Form S-1 (File
No. 333-288391).

 Please call Elliott Smith
of Perkins Coie LLP at (212) 261-6847 should you require further information.

 [ Signature Page Follows ]

 Very truly yours,

 By:
 /s/ Sten Gustafson

 Name:
 Sten Gustafson

 Title:
 Chief Financial Officer

 cc:
 Elliott Smith, Perkins Coie LLP

CORRESP
 1
 filename1.htm

 UBS Securities LLC

 1285 Avenue of the Americas

 New York, NY 10019

 July 14, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, DC 20549

 Attention: Benjamin Holt

 Re:
 Pyrophyte Acquisition Corp. II

 Registration
Statement on Form S-1

 Initially filed
June 27, 2025, as amended

 File No. 333-
288391

 Dear Mr. Holt,

 On July 11, 2025, the undersigned,
as representative of the underwriters in the offering subject to the registration statement referred to above, joined in the request of
Pyrophyte Acquisition Corp. II that the effective date of the registration statement be accelerated so as to permit it to become effective
at 4:00 p.m. ET on Monday, July 14, 2025, or as soon thereafter as practicable. We hereby withdraw our request until further notice.

 [Signature page follows]

 Sincerely,

 UBS Securities LLC

 By :
 / s/ Adam Kerbis

 Name: Adam Kerbis

 Title: Executive Director

 By :
 /s/ Alex Cahail

 Name: Alex Cahail

 Title: Director

 [Signature Page to Underwriters' Acceleration
Withdrawal]

CORRESP
 1
 filename1.htm

 Pyrophyte Acquisition Corp. II

 3262 Westheimer Road, Suite 706

 Houston, Texas 77098

 July 11, 2025

 VIA EDGAR

 Benjamin Holt

 Division of Corporation Finance

 Office of Real Estate & Construction

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, DC 20549-3233

 Re:
 Pyrophyte Acquisition Corp. II

 Registration Statement on Form S-1

 Filed June 27, 2025, as amended

 File No. 333-288391

 Dear Mr. Holt:

 Pursuant to Rule 461 of the
rules and regulations promulgated under the Securities Act of 1933, as amended, Pyrophyte 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. Eastern
Time on July 14, 2025, or as soon thereafter as practicable.

 Please call Elliott Smith
of Perkins Coie LLP at (212) 261-6847 to provide notice of the effectiveness of the Registration Statement.

 [ Signature Page Follows ]

 Very truly yours,

 By:
 /s/ Sten Gustafson

 Name:
 Sten Gustafson

 Title:
 Chief Financial Officer

 cc: Elliott Smith, Perkins Coie LLP

 [ Signature Page to Acceleration Request ]

CORRESP
 1
 filename1.htm

 UBS Securities LLC

 1285 Avenue of the Americas

 New York, NY 10019

 July 11, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, DC 20549

 Attention: Benjamin Holt

 Re:

 Pyrophyte Acquisition Corp. II
 Registration Statement on Form S-1
Initially filed June 27, 2025, as amended
File No. 333- 288391

 Dear Mr. Holt,

 Pursuant to Rule 461 under the
Securities Act of 1933, as amended (the "Act"), the undersigned, as representative of the underwriters in the offering subject
to the registration statement referred to above, hereby joins in the request of Pyrophyte 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 Monday, July 14,
2025, or as soon thereafter as 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]

 Sincerely,

 UBS Securities LLC

 By:
 /s/ Adam Kerbis

 Name:
 Adam Kerbis

 Title:
 Executive Director

 By:
 /s/ Alex Cahail

 Name:
 Alex Cahail

 Title:
 Director

 [Signature Page to Underwriters'
Acceleration Request]