SecProbe.io

CORRESP
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 U.S. Securities and Exchange Commission
 Division of Corporation Finance
 Office of Energy & Transportation
 100 F Street, N.E.
 Washington, D.C. 20549

 October 8, 2025

 Re:
 Rubico Inc.

 Registration Statement on Form F-1

 Filed September 22, 2025

 File No. 333-290426

 Ladies and Gentlemen:

 This letter sets forth the response of Rubico Inc. (the " Company ") to the comment letter dated September 25, 2025 (the " Comment Letter ") of the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ") with respect to the Company's registration statement on Form F-1 (the " Registration Statement "), that was filed with the Commission on September 22, 2025. The Company is today filing via EDGAR this letter together with an amended Registration Statement (the " Amended Registration Statement "), which responds to the Staff's comments contained in the Comment Letter, and contains as well certain updated, revised and supplemental information.

 Capitalized terms used in this letter that are not otherwise defined herein have the meanings ascribed to them in the Amended Registration Statement. The following numbered paragraphs correspond to the numbered paragraphs in the Comment Letter.

 Registration Statement on Form F-1

 Cover Page

 1. We note you disclose that if all of the Warrants offered to investors in this offering, including those subject to the Representative's over-allotment option for Warrants, are exercised on a zero cash basis, a maximum of 13,967,608 shares could be issued upon such zero cash exercise without payment to the Company of any additional cash. Please expand your disclosure to provide an example regarding the maximum number of shares issuable under the Warrants for the Representative's over-allotment option for Warrants.

 2

 The Company has revised the disclosure in the Amended Registration Statement in response to the Staff's comment.

 * * * * *

 If you have any questions or comments concerning this letter, please feel free to contact Will Vogel at the undersigned at 212-922-2280.

 Yours sincerely

 Watson Farley & Williams LLP

 /s/ Watson Farley & Williams LLP

September 25, 2025
Kalliopi Ornithopoulou
Chief Executive Officer, President, and Chairwoman of the Board
Rubico Inc.
20 Iouliou Kaisara Str
19002 Paiania
Athens, Greece
Re:Rubico Inc.
Registration Statement on Form F-1
Filed September 22, 2025
File No. 333-290426
Dear Kalliopi Ornithopoulou:
            We have conducted a limited review of 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.
Registration Statement on Form F-1
Cover Page
1.We note you disclose that if all of the Warrants offered to investors in this offering,
including those subject to the Representative’s over-allotment option for Warrants, are
exercised on a zero cash basis, a maximum of 13,967,608 shares could be issued upon
such zero cash exercise without payment to the Company of any additional
cash. Please expand your disclosure to provide an example regarding the maximum
number of shares issuable under the Warrants for the Representative's over-allotment
option for Warrants.

September 25, 2025
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 Karina Dorin at 202-551-3763 or Daniel Morris at 202-551-3314 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Will Vogel, Esq., of Watson Farley & Williams LLP

CORRESP
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 U.S. Securities and Exchange Commission
 Division of Corporation Finance
 Office of Energy & Transportation
 100 F Street, N.E.
 Washington, D.C. 20549

 September 17, 2025

 Re: 	Rubico Inc.

 Draft Registration Statement on Form F-1

 Submitted August 22, 2025

 CIK No. 0001943421

 Ladies and Gentlemen:

 This letter sets forth the response of Rubico Inc. (the " Company ")
to the comment letter dated September 9, 2025 (the " Comment Letter ") of the staff (the " Staff ")
of the U.S. Securities and Exchange Commission (the " Commission ") with respect to the Company's draft registration
statement on Form F-1 (the " Registration Statement "), that was confidentially submitted to the Commission for review
on August 22, 2025. The Company is today publicly filing via EDGAR this letter together with a revised Registration Statement, which responds
to the Staff's comments contained in the Comment Letter, and contains as well certain updated, revised and supplemental information.

 Capitalized terms used in this letter that are not otherwise defined herein
have the meanings ascribed to them in the Registration Statement. The following numbered paragraphs correspond to the numbered paragraphs
in the Comment Letter.

 Draft Registration Statement on
Form F-1

 General

 1. We note you disclose that the lower that the stock price of your common shares is on the First Reset
Date and Second Reset Date, the more shares that will be issuable pursuant to the Warrants. Please expand your disclosure to also
discuss, if true, that the number of shares issuable on the exercise of the Warrants under the zero cash exercise option increases as
the stock price falls further below the applicable exercise price of the Warrants.

 The Company has revised the Registration Statement
in response to the Staff's comment.

 Page 2

 2. We note that certain disclosures appear to not have been updated following the consummation of the
Spin-Off. In this regard, we note you disclose on page 11 that the "offering is conditioned on the consummation of the Spin-Off and
commencement of trading on [y]our common shares on Nasdaq." However, you also disclose on page 3 that the Spin-Off distribution
was consummated and your common shares began trading on Nasdaq on August 4, 2025. Please revise your prospectus to ensure your
disclosures are current.

 The Company has revised the Registration Statement
in response to the Staff's comment.

 * * * * *

 If you have any questions or comments concerning this letter, please feel
free to contact Will Vogel at the undersigned at 212-922-2280.

 Yours sincerely

 Watson Farley & Williams LLP

 /s/ Watson Farley & Williams LLP

CORRESP
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 Seaport Global Securities LLC

 360 Madison Avenue, 22nd Floor

 New York, NY 10017

 September 18, 2025

 Via EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 Washington, D.C.
20549

 Attention : Michael Purcell

 RE:
 Rubico Inc.

 Registration Statement on Form F-1

 File No. 333-288796

 Request for Acceleration

 Ladies and Gentlemen:

 Seaport Global Securities LLC, solely acting
as qualified independent underwriter in connection with the secondary offering of shares of common stock of Rubico Inc., issued in an
equity line pursuant to the registration statement on Form F-1, as amended (File No. 333-288796) (the " Registration Statement "),
hereby concurs in the request by Rubico Inc. that the effective date of the above-referenced registration statement be accelerated to
4:00P.M. (Eastern Time), or as soon as practicable thereafter, on September 19, 2025, pursuant to Rule 461 under the Securities Act.
Seaport Global Securities LLC affirms that it is aware of its obligations under the Securities Act as they pertain to the equity line
offering pursuant to the Registration Statement.

 [Signature Page Follows]

 Very truly yours,

 SEAPORT GLOBAL SECURITIES LLC

 cc: Dean Colucci, Duane Morris LLP

 [ Signature Page to Acceleration Request ]

CORRESP
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 Rubico Inc.

 20 Iouliou Kaisara Str

 19002 Paiania

 Athens, Greece

 September 18, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549

 Re:
 RUBICO Inc.

 Registration Statement on Form F-1

 Originally filed on August 13, 2025

 File No. 333-289552

 Ladies and Gentlemen:

 The undersigned registrant hereby requests that the
effectiveness of the above captioned Registration Statement on Form F-1, that was originally filed with the U.S. Securities and Exchange
Commission on August 13, 2025, be accelerated so that it will be made effective at 4:00 p.m. Eastern time on September 19, 2025, or as
soon thereafter as practicable, pursuant to Rule 461(a) of the Securities Act of 1933, as amended (the “ Act ”).

 The undersigned registrant is aware of its obligations
under the Act.

 Should you have any questions regarding this request,
please do not hesitate to contact Will Vogel at (212) 922-2280 of Watson Farley & Williams LLP, counsel to the undersigned registrant.

 Yours truly,

 RUBICO INC.

 By:
 /s/ Nikolaos Papastratis

 Name: Nikolaos Papastratis

 Title: Chief Financial Officer

CORRESP
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 Rubico Inc.

 20 Iouliou Kaisara Str

 19002 Paiania

 Athens, Greece

 September 17, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549

 Re:
 RUBICO Inc.

 Registration Statement on Form F-1

 Originally filed on July 21, 2025

 File No. 333-288796

 Ladies and Gentlemen:

 The undersigned registrant hereby requests that the effectiveness of the
above captioned Registration Statement on Form F-1, that was originally filed with the U.S. Securities and Exchange Commission on July
21, 2025, be accelerated so that it will be made effective at 4:00 p.m. Eastern time on September 19, 2025, or as soon thereafter as practicable,
pursuant to Rule 461(a) of the Securities Act of 1933, as amended (the " Act ").

 The undersigned registrant is aware of its obligations under the Act.

 Should you have any questions regarding this request, please do not hesitate
to contact Will Vogel at (212) 922-2280 of Watson Farley & Williams LLP, counsel to the undersigned registrant.

 Yours truly,

 RUBICO INC.

 By:
 /s/ Nikolaos Papastratis

 Name: Nikolaos Papastratis

 Title: Chief Financial Officer

September 9, 2025
Kalliopi Ornithopoulou
Chief Executive Officer, President, and Chairwoman of the Board
Rubico Inc.
20 Iouliou Kaisara Str
19002 Paiania
Athens, Greece
Re:Rubico Inc.
Draft Registration Statement on Form F-1
Submitted August 22, 2025
CIK No. 0001943421
Dear Kalliopi Ornithopoulou:
            We have conducted a limited review of your draft registration statement and have the
following comments.
            Please respond to this letter by providing any requested information and by publicly
filing your registration statement and non-public draft submission 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 filed
registration statement, we may have additional comments.
Draft Registration Statement on Form F-1
General
1.We note you disclose that the lower that the stock price of your common shares is on
the First Reset Date and Second Reset Date, the more shares that will be issuable
pursuant to the Warrants. Please expand your disclosure to also discuss, if true, that
the number of shares issuable on the exercise of the Warrants under the zero cash
exercise option increases as the stock price falls further below the applicable exercise
price of the Warrants.
We note that certain disclosures appear to not have been updated following the
consummation of the Spin-Off. In this regard, we note you disclose on page 11 that
the "offering is conditioned on the consummation of the Spin-Off and commencement
of trading on [y]our common shares on Nasdaq.” However, you also disclose on page 2.

September 9, 2025
Page 2
3 that the Spin-Off distribution was consummated and your common shares began
trading on Nasdaq on August 4, 2025. Please revise your prospectus to ensure your
disclosures are current.
            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.
            We also remind you that your registration statement and non-public draft submission
must be on file at least two business days prior to the requested effective date and time. 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 Timothy S. Levenberg at 202-551-3707 or Karina Dorin at 202-551-
3763 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Will Vogel, Esq., of Watson Farley & Williams LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 22, 2025

Nikolaos Papastratis
Chief Financial Officer
Rubico Inc.
20 Iouliou Kaisara Str
19002 Paiania
Athens, Greece

 Re: Rubico Inc.
 Registration Statement on Form F-1
 Filed August 13, 2025
 File No. 333-289552
Dear Nikolaos Papastratis:

 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 Anuja Majmudar at 202-551-3844 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Will Vogel
</TEXT>
</DOCUMENT>

CORRESP
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 U.S. Securities and Exchange Commission
 Division of Corporation Finance
 Office of Energy & Transportation
 100 F Street, N.E.
 Washington, D.C. 20549

 August 20, 2025

 Re: Rubico Inc.

 Registration Statement on Form F-1
 Filed July 21, 2025
 File No. 333-288796

 Ladies and Gentlemen:

 This letter sets forth the response of Rubico Inc. (the " Company ")
to the letter dated August 12, 2025 (the " Comment Letter ") of the staff (the " Staff ") of the U.S.
Securities and Exchange Commission (the " Commission ") with respect to the Company's registration statement on
Form F-1, File No. 333-288796 (the " Registration Statement "), that was filed with the Commission on July 21, 2025.

 The Company has today filed via EDGAR Amendment No. 1 to the Registration
Statement (the " Amended Registration Statement "), which responds to the Staff's comments contained in the Comment
Letter. The Amended Registration Statement also includes certain updates related to the passage of time.

 Capitalized terms used in this letter that are not otherwise defined herein
have the meanings ascribed to them in the Amended Draft Registration Statement. The following numbered paragraphs correspond to the numbered
paragraphs in the Comment Letter.

 Registration Statement on Form F-1

 General

 1. Please update your registration statement to reflect the commencement of trading on the Nasdaq Capital
Market, as disclosed in your 6-K filed on August 4, 2025.

 The Company has revised the Amended Registration Statement in response
to the Staff's comment.

 2. Please clarify whether, and if so, how, the purchase agreement contemplates the "put" of
preferred stock purchase rights to the selling shareholder. In this regard, we note that the purchase agreement does not seem to refer
to these rights which appear to have been a dividend for each common share outstanding prior to the spinoff. In addition, please address
why you believe inclusion of the rights complies with Securities Act Sections Compliance and Disclosure 139.13.

 The Company respectfully acknowledges the Staff's comment and provides
the following response:

 Prior to the entry into the purchase agreement, on a registration statement
on Form 20-F effective on June 23, 2025, the Company registered under the Exchange Act the following class of securities: "shares
of common stock, par value $0.01, including the Preferred Stock Purchase Rights." As disclosed in this registration statement and
pursuant to the terms of the shareholders' rights agreement which was described in and a form of which was filed with this registration
statement, a Preferred Stock Purchase Right (a " Right ") was attached to every common share distributed in the spin-off
distribution and will attach to every common share issued after the spin-off distribution (until the Rights distribution date). As further
described in this Exchange Act registration statement, the Rights will not be separable from and will trade with the common shares, and
ownership of the Rights is evidenced by ownership of the common shares and not by separate Rights certificates. Both with respect to the
foregoing terms of the Rights and in general, the terms of the Company's shareholders' rights agreement conforms to the established
market standard for such agreements.

 As a consequence, every common share purchased by the selling shareholder
under the purchase agreement will necessarily include an attached Right. The Company and the selling shareholder have entered into a binding
agreement for the sale and purchase of common shares. Because the common shares include the Rights, the purchase agreement necessarily
contemplates the sale of the Rights and constitutes a binding agreement for the sale and purchase of the Rights attached to the common
shares. The Company respectfully submits that inclusion of the Rights therefore complies with Securities Act Sections Compliance and Disclosure
139.13.

 * * * * *

 If you have any questions or comments concerning this letter, please feel
free to contact Will Vogel at the undersigned at 212-922-2280.

 Yours sincerely

 Watson Farley & Williams LLP

 /s/ Watson Farley & Williams LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 12, 2025

Nikolaos Papastratis
Chief Financial Officer
Rubico Inc.
20 Iouliou Kaisara Str
19002 Paiania
Athens, Greece

 Re: Rubico Inc.
 Registration Statement on Form F-1
 Filed July 21, 2025
 File No. 333-288796
Dear Nikolaos Papastratis:

 We have conducted a limited review of 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 F-1
General

1. Please update your registration statement to reflect the commencement of
trading on
 the Nasdaq Capital Market, as disclosed in your 6-K filed on August 4,
2025.
2. Please clarify whether, and if so, how, the purchase agreement
contemplates the "put"
 of preferred stock purchase rights to the selling shareholder. In this
regard, we note
 that the purchase agreement does not seem to refer to these rights which
appear to
 have been a dividend for each common share outstanding prior to the
spinoff. In
 addition, please address why you believe inclusion of the rights
complies with
 Securities Act Sections Compliance and Disclosure 139.13.
 August 12, 2025
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 Michael Purcell at 202-551-5351 or Daniel Morris at
202-551-3314
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Will Vogel
</TEXT>
</DOCUMENT>