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CORRESP
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 filename1.htm

 SWARMER,
INC
 4515 Seton Center Pkwy #330
Austin, TX 78759

 June 10, 2026

 VIA EDGAR

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

 Attention: Alexandra Barone

 Re:
 Swarmer, Inc

 Registration Statement on Form S-1

 File No. 333-296678

 Request for Acceleration of Effective Date

 Ladies and Gentlemen:

 Pursuant to Rule 461
of Regulation C promulgated under the Securities Act of 1933, as amended, Swarmer, Inc (the "Registrant") hereby requests
that the U.S. Securities and Exchange Commission (the "Commission") accelerate the effective date of the above-referenced
Registration Statement on Form S-1 (as amended to date, the "Registration Statement") and declare the Registration Statement
effective as of 9:00 a.m. Eastern time, on June 15, 2026, or as soon thereafter as possible, or at such other time as its legal counsel,
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. ("Mintz"), may request by telephone to the staff of the Commission.

 Once the Registration Statement
has been declared effective, please orally confirm that event with Daniel Bagliebter of Mintz at (212) 692-6856 or, in his absence, Kostantinos
Skordalos of Mintz at (212) 692-6294.

 Under separate cover, you
will receive today a letter from the managing underwriter of the proposed offering joining in the Registrant's request for acceleration
of the effectiveness of the Registration Statement.

 [Signature Page Follows.]

 Very truly yours,

 SWARMER, INC

 By:
 /s/ Alexander Fink

 Name:
 Alexander Fink

 Title:
 Chief Executive Officer (U.S.) and President

 cc:            Swarmer,
Inc

 Serhii Kupriienko

 Brooks Ensign

 Jennifer DeTrani

 Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

 Kenneth
Koch , Esq.

 Daniel Bagliebter, Esq.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 12, 2026

Alexander Fink
Chief Executive Officer (U.S.)
Swarmer, Inc
4515 Seton Center Pkwy #330
Austin, TX 78759

 Re: Swarmer, Inc
 Draft Registration Statement on Form S-1
 Submitted May 12, 2026
 CIK No. 0002092574
Dear Alexander Fink:
 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
non-public draft
submission on EDGAR at least two business days prior to the requested effective
date and time.
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 Alexandra Barone at 202-551-8816 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Daniel Bagliebter, Esq.
</TEXT>
</DOCUMENT>