MD&A

We respectfully acknowledge the Staff's comment and are providing additional details and references to identify the materiality considerations that we used when determining the items to disclose in MD&A, as well as the referenced rate reconciliation contained within Note 14, Income Taxes. The “one-time tax adjustment” referenced as a cash flow benefit on page 23 in Liquidity and Capital Resources relates to changes to the timing of deduction of previously capitalized domestic research and development expenses under IRC Section 174 from the One Big Beautiful Bill Act. We are deducting the remaining unamortized domestic research and development costs over two years (half in 2025 and the other half in 2026). As shown in the deferred tax table of Note 14, Income Taxes, this tax adjustment reduced “Intangible” deferred tax assets and corresponding 2025 U.S. federal estimated income tax…

The Company respectfully acknowledges the Staff’s comment and refers the Staff to its response to comment 1 above for future disclosures regarding the number of quarterly unique active providers using its workflow tools. The Company notes that user engagement metrics have been referenced on earnings calls periodically, primarily in response to analyst and investor questions from prior periods, to provide supplemental context regarding platform activity. These references were not intended to convey that management relies on such metrics to evaluate financial condition or allocate resources. The majority of the engagement metrics identified in the Staff's comment were referenced qualitatively, without quantification, over the relevant periods. The one metric that was consistently quantified — the number of unique active providers using workflow tools — is the same metric the Company is…

The Company considered the requirements of Item 303(b) of Regulation S-K in preparing its MD&A for the quarterly period ended January 3, 2026, including whether to separately discuss changes in segment income from operations, which is the primary segment profitability measure reviewed by the Chief Operating Decision Maker (“CODM”) and disclosed in Note 15 to the consolidated condensed financial statements. As disclosed in Note 15, the CODM evaluates performance and allocates resources primarily based on income from operations, and the CODM is regularly provided with segment-level revenue, cost of sales, selling, general and administrative (“SG&A”) expense, and research and development (“R&D”) expense in evaluating segment performance and allocating resources. This is reflected in the Company’s segment footnote disclosures, including the enhanced disclosures in accordance with ASU…

The Company acknowledges the Staff’s comment and the guidance in Item 303(b) of Regulation S-K. In preparing the MD&A, the Company identified multiple factors contributing to period-to-period changes in net revenue and other income statement line items, including changes in volume, product and customer mix, pricing, and other factors. In response to the Staff’s comment, the Company will revise its future filings to quantify, where possible, the impact of each material contributing factor, including any offsetting factors, in dollars and/or percentages, and to expand its discussion of the underlying reasons driving these changes. The Company will apply this enhanced level of quantification and transparency consistently throughout its MD&A discussion for all material income statement line items, as applicable. The Company provides the following illustrative example of the disclosure for…

The Company acknowledges the Staff’s comment and advises the Staff that it has revised the italicized disclosure at the beginning of the Management’s Discussion and Analysis of Financial Condition and Results of Operations section by adding the bolded language below to page 95 of the Revised Registration Statement to (i) clarify that the historical financial data presented is that of Yellowstone Midco Holdings, LLC, (ii) explain why the Company has not separately presented the historical financial data of the registrant, and (iii) discuss the October 3, 2025 merger between the registrant and Yellowstone Midco Holdings, LLC and pending Corporate Conversion: We currently operate as a Delaware limited liability company under the name Yellowstone Midco Holdings II, LLC, which was formed on September 4, 2025 and directly and indirectly holds all of the equity interests in our operating…

The Company acknowledges the Staff’s comment and has revised its disclosures on pages 96 and 99 of the Revised Registration Statement to provide the requested detailed quantification for each period presented. This includes a breakout of aggregate gross favorable and gross unfavorable EAC adjustments. For any material specific contract that contributed to a gross favorable or unfavorable EAC adjustment, the Company has included additional disclosure for the quantification and the nature of the adjustment. Furthermore, the Company has quantified the total amount of EAC adjustments recognized during the period that are attributable to contracts currently in a loss position. The Company respectfully advises the Staff that there were no specific individual contracts that met the Company’s quantitative or qualitative materiality threshold that would require additional disclosure as a…

The Company respectfully advises the Staff that the waiver relates to the legal entity whose financial statements were provided to the lender. The debt covenants required the provision of the financial statements of Yellowstone Borrower, LLC. Due to the planned offering, the Company provided the financial statements of Yellowstone Midco Holdings, LLC and obtained a waiver to acknowledge that change. In response to the Staff’s comment, the Company has added the following bolded language to Note 7 on page F-48 of the unaudited interim financial statements and Note 6 on page F-22 of the audited annual financial statements: The waiver relates to the provision of Yellowstone Midco Holdings, LLC’s consolidated financial statements to the borrower as opposed to the financial statements of Yellowstone Borrower, LLC, a subsidiary of the Company, as required by the Term Loan Facility. The Company…

We acknowledge the Staff’s comment and respectfully advise the Staff that in future Annual Reports on Form 20-F beginning with the year ended December 31, 2025, we will expand our Item 5. Operating and Financial Review and Prospects (“MD&A”) to provide a more substantive analysis of the reasons for changes in revenue during the periods presented. Specifically, the expanded discussion will, if applicable and practicable, address material impacts from pricing adjustments and material impacts from our customer base development, including contributions from new customer acquisitions as well as from existing customers. As noted in our response below to the Staff’s comment #4, we do not currently disclose or internally use GAAP revenue by product. However, if this were to change in the future, we would also evaluate whether there are any material impacts from new or expanded product lines…

The material amount of the deferred tax asset valuation allowance relates to the net operating loss carryforwards in our foreign jurisdictions, primarily in the UK, Germany, and Canada. These foreign net operating loss carryforwards total $46 million of the deferred tax asset valuation allowance at December 31, 2024. The negative evidence considered was the three-year cumulative loss analysis at the entity and jurisdictional level. We could not identify enough positive evidence, through forecasts, the reversal of deferred tax liabilities, or tax planning strategies to overcome the negative evidence from the three-year cumulative loss. In addition, $6 million of the deferred tax asset valuation allowance relates to other foreign components of the deferred tax asset at December 31, 2024, primarily deferred compensation from restricted stock units and cash debentures. The negative evidence…

The disclosure on pages 22 and 188 of Amendment No. 1 has been revised in accordance with the Staff’s comment. Interests of Certain Persons in the Business Combination, page 18

In response to the Staff’s comment, the Company has revised the Registration Statement to include the comparative financial statements for the six months ended May 31, 2024, and has expanded the MD&A section to provide a discussion of the material variances between the six-month periods ended May 31, 2025 and May 31, 2024. Note 18, page F-82

The Company acknowledges the Staff’s comment. FASB ASC 450-20-50-4 requires, if a loss contingency is reasonably possible, disclosure of the nature of the contingency and an estimate of the possible loss or range of loss or a statement that such an estimate cannot be made. The Company respectfully confirms that in each of the matters referenced on pages 123 through 129 of its Annual Report on Form 10-K for the year ended December 31, 2024 (the “ Annual Report ”), the Company is unable to estimate a range of potential losses due to the early stage of proceedings, factual disputes, uncertainty regarding the plaintiffs’ or relevant government agencies’ damages or penalties sought, and the inherent uncertainty in the legal process. In addition, except to the limited extent noted below, the respective plaintiffs and state or federal governmental agencies, as applicable, have not specified…

In response to the Staff’s comment, the Company records a warranty reserve, as part of and in connection with its product sales related to the initial one-year manufacturer warranty. This is for the period prior to any extended warranty period for maintenance optionally purchased. The amount of the reserve has remained consistent from period to period as a result of the Company’s limited historical first year warranty claims experience. Warranty claims have been infrequent and insignificant in dollar amount. ​ In evaluating the adequacy of the reserve, management considered the requirements of ASC 460-10, Guarantees , and ASC 450-20, Loss Contingencies . Based on both historical trends, and expected future claims, the Company has determined that the reserve balance is appropriate and that related warranty expense is immaterial to the Company. ​ Given the immateriality of the reserve and…

The Company acknowledges that both operating income and adjusted operating income by segment have been disclosed in our Management’s Discussion and Analysis (“MD&A”) in referenced Form 10-K. However, operating income by segment is not included in the financial information regularly provided to the Company’s Chief Operating Decision Maker (“CODM”), while adjusted operating income by segment is included in the financial information regularly provided to the CODM. As disclosed in “Note 16 – Business Segments Information” in our Form 10-K for fiscal year-ended January 31, 2025, adjusted operating income is the only measure of segment profit or loss used by the CODM to assess segment performance and make resource allocation decisions. Therefore, the Company confirms that adjusted operating income by segment is the only measure of segment profit or loss required to be disclosed pursuant to…

The Company respectfully acknowledges the Staff’s comment and confirms that the amount of license revenue recognized from the term-license software subscriptions (including related maintenance revenue) is less than ten percent of total revenues and less than three percent if excluding maintenance revenue, therefore, the Company’s presentation of revenue complies with Rule 5-03(b)(1)(a) of Regulation S-X. Further, the Company has considered the guidance in ASC 606-10-50-1 in evaluating whether and how its disclosures should disaggregate revenues. This assessment requires judgment, depends on various entity-specific and industry-specific factors and is not subject to any one prescribed factor as the basis for disaggregation. The Company has evaluated the guidance in ASC 606-10-50-5 through 50-7 and the related implementation guidance in ASC 606-10-55-89 through 55-91 with respect to the…

The Company respectfully acknowledges the Staff’s comment. Upon further review of SEC Release No. 33-10751, the Company does not believe orders, backlog, inventory or fill-rates represent key variables that would be necessary for an investor to understand the Company’s financial condition, changes in financial condition and results of operations. The Company separately discloses sales as a key financial measure utilized by the Company’s executive management and operating units in order to evaluate the results of its business and in understanding key variables impacting the current and future results of the Company. As a result, in future filings, beginning with its Annual Report on Form 10-K for the year ending December 31, 2025, the Company will remove the referenced disclosure. www.lincolnelectric.com United States Securities and Exchange Commission Division of Corporate Finance…

We will revise the table for the reconciliation of Total Adjusted EBITDA to begin with the GAAP measure of Net income attributable to Gannett, consistent with the guidance set forth in Question 102.10(b) of the Commission’s Compliance and Disclosure Interpretations for Non-GAAP Financial Measures. We will include the revised presentation in future filings, beginning with the Company’s quarterly report on Form 10-Q for the quarter ending September 30, 2025 and in future earnings releases furnished on Form 8-K, including revisions to Table 5, as applicable. * * * * * If you have any questions or comments regarding these responses or require any additional information, please do not hesitate to contact me at tgosser@gannett.com or (571) 405-0574. Very truly yours, /s/ Trisha Gosser Trisha Gosser Chief Financial Officer

The Company acknowledges the Staff’s comment and respectfully notes a discussion of the Chicago Metropolitan area and the competition the Company faces in its primary market under the section captioned “Market Area and Competition” on page 63 of the Amended Registration Statement. The Company has also included additional disclosure in the Amended Registration Statement in this risk factor and the risk factor tiled “ Our business strategy includes commercial real estate (including commercial construction) and commercial and industrial loan growth, and our financial condition and results of operations could be negatively affected if we fail to grow or fail to manage our growth effectively ” on page 17 as well as a cross reference on page 50 in the MD&A section to the discussion under the section captioned “Market Area and Competition.” We are subject to certain risk if we are able to grow…

The Company respectfully acknowledges the Staff’s comments regarding our disclosures in the 2024 Annual Report on page 8 related to the ADG RNG projects under the TotalEnergies JV, bp JV, as well as the Company owned projects and the related observations concerning the MD&A discussions on pages 35 and 37. The Company further acknowledges the Staff’s comment regarding the revised estimates of annual RNG production under the TotalEnergies JV and bpJV arrangements. The Company respectfully responds to each comment in turn: i) Actual levels of production for each period The Company respectfully acknowledges the Staff’s request for expanded disclosure of current levels of production as of the time of the applicable disclosure period. In response, the Company confirms the Company’s 2024 Annual Report disclosure that one project under the TotalEnergies JV and five of six projects under the…

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised Amendment No. 2 on pages 146-149 in response, consistent with its response contained in the July Response Letter. Loan Portfolio, page 182

The Company respectfully acknowledges the Staff’s comment. The Company has reviewed ASC 280-10-50-40 and, as noted above, if the Staff so requires, would plan to revise and update its discussion of revenue performance by its respective products in the notes to the financial statements and in the MD&A section of the 2025 Form 10-K. • As part of your response, please provide us with a sample breakdown of revenue from the three IG products for recent periods.

The Company acknowledges the Staff’s comment and has revised pages 2, 41 and 45 accordingly.

We respectfully advise the Staff that we have updated the corresponding amounts in the “ Unaudited Condensed Consolidated Financial Statements ” for the six months ended December 31, 2024 and 2023 and page F-34, of the Amendment No. 3. We thank the Staff for its review of the foregoing. If you have any further comments or questions, please feel free to contact to our counsel, Wei Wang, at wwang@egsllp.com or by telephone at (212) 370-1300. Sincerely, /s/ Jinchun Cheng Jinchun Cheng, Chief Executive Officer cc: Wei Wang, Esq. Ellenoff Grossman & Schole LLP

The Company acknowledges the Staff’s comment and respectfully submits that its current MD&A disclosure already provides appropriate information regarding PIK income from portfolio companies. Specifically, the Company notes that the current MD&A disclosure lists “PIK income” as a separate line item when summarizing and disaggregating its investment income components for the applicable periods and also provides narrative disclosure regarding material changes in PIK income from period to period. The Company undertakes to disclose in the MD&A the number of portfolio companies that were restructured during the applicable period covered by the MD&A. July 31, 2025 Page 2 2.

The Company undertakes to include the requested disclosure in future SEC filings. 3.

The Company respectfully advises the Staff that in future filings, until such time as the Company has fully integrated the Omni Acquisition, the Company will include the following in its MD&A disclosures (i) any ongoing issues related to the Omni integration including related uncertainties and concerns that are reasonably likely to have a material effect on the integration of the Omni business and (ii) any changes in circumstance that have occurred since the Company’s initial expectations regarding the anticipated benefit of the Omni Acquisition that the Company believes are reasonably likely to cause a material adverse change in the expectations that were conveyed and the reason for the Company’s assessment. By way of example, with respect to the quarter ended June 30, 2025, the Company plans to include the following disclosure in the MD&A section of its Quarterly Report on Form 10-Q…

We have removed the pro forma income tax disclosures from the faces of our historical financial statements Certain Relationships and Related Party Transactions Member Distribution, page 86

The Company notes the staff’s comments and responds as follows: (a) The Company records cost of sales based on the direct materials and labor required to produce finished dental prosthetics. Since inception, the Company has maintained a standardized product pricing list, which includes embedded labor and material cost assumptions. Payments made to the subcontracted operator are disaggregated between cost of goods sold and sales and marketing expenses based on the underlying services rendered. (b) The following table, which has been added to Note 8 of the financial statements presented in Amendment No. 3, presents a breakdown of revenue, cost of goods sold, and selling and marketing expenses (included within general and administrative expenses) for each year: 2024 2023 2022 Revenue $ 284,095 $ 339,466 $ 173,329 Cost of goods sold 166,610 197,860 101,054 Gross Profit 117,485 141,606…

We agree with the Staff’s suggestion that disclosing net sales by brand would enhance the meaningfulness of our current practice of reporting in MD&A the book values of indefinite-lived trademarks for each brand whose net sales equaled or exceeded 3% of our net sales. Accordingly, we plan to include in MD&A in future filings disclosures of net sales by brand for each brand whose net sales equaled or exceeded 3% of our net sales. These disclosures will be similar to the individual brand net sales disclosures that had previously appeared in our financial statement footnotes prior to our transition to four reportable segments. Consolidated Financial Statements (3) Acquisitions and Divestitures Divestiture of Green Giant U.S. Shelf-Stable Product Line, page 69

In response to the Staff’s comment, the Company has included a discussion of the warrant agreement and the phantom awards and their expected impact in the Company’s cash obligations and results of operations under the heading “Liquidity and Capital Resources.” The Company notes that the warrant is exercisable for shares and may not be settled in cash. Consolidated Financial Statements, page F-1

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it intends to include the additional disclosure below as a new subsection under “Management’s Discussion and Analysis of Financial Condition and Results of Operations一Factors Affecting Our Performance一Our Ability to Maintain Best-In-Class Underwriting Capabilities and Achieve Low Consumer Credit Losses” in Amendment No. 2 in response. Such disclosure will be supplemented in Amendment No. 2 as needed with relevant data for the recently completed fiscal quarter ended June 30, 2025, which is not currently available. Credit Risk Governance and Monitoring We evaluate the repayment ability of our consumers both at origination and post-origination through a structured governance and monitoring framework. On an operational level, our underwriting teams conduct daily and weekly cohort-level monitoring to flag…

While we acknowledge the Staff’s comment to include additional product and/or product type disclosures in our MD&A, we note that you suggested additional disclosure in an area that we believe already contains robust disclosure. As a result, we have consulted with our external advisors in connection with your comment. We respectfully note that Item 303 of Regulation S-K requires that the MD&A address material period-over-period changes in financial statement line items, including through a quantitative and qualitative discussion of the underlying reasons for those changes. With respect to specific segment and product line information, Item 303 gives broad deference to the registrant, noting that this level of disclosure is required to the extent, “in the registrant’s judgement,” it “would be necessary to an understanding of such business.” For the reasons outlined below, we believe our…

The Company respectfully acknowledges the Staff’s comment and submits to the Staff that the Company interprets the guidance in SAB 11:B to require a particular July 9, 2025 Page 3 presentation, including parenthetical disclosure, when there is depreciation, depletion and amortization attributable to revenue producing activity that is excluded from cost of goods sold. The Company purchases all finished goods from third party suppliers under contract manufacturing arrangements. Since the Company does not manufacture any of its products, it does not own or operate any equipment used in the manufacturing process of its products. Given that the Company does not own any such equipment, the Company believes that cost of goods sold includes all appropriate costs to bring inventory to a salable state and that gross profit is appropriately presented. Further, the Company’s depreciation related to…

In response to the Staff’s comment, the Company has updated the Summary Statements of Operations Data table on page 12, statements of operations on pages F-3 and F-30 of the Amended Registration Statement to reflect the pro forma income tax calculation. Additionally, the Company has included disclosure on pages 43 and 48 of the MD&A discussing the potential impact of its anticipated status as a taxable entity. Page 37 was updated to reflect the reclassification of the undistributed losses. Risk Factors Risks Relating to Our Business We rely on Floorplan Financing, page 19

In response to the Staff’s comment, the Company has revised the disclosure of its revenue recognition accounting policy on page 50 and page F-38 to include a discussion of principal versus agent considerations, the fair value valuation of trade-ins, and disclosure regarding where and how the interest-bearing assets financed by the Company are recorded in the combined financial statements. In addition, the Company has removed the discussion of the repurchase agreements may be required under certain financing arrangements. Note 15. Related Parties Transactions, page F-21

We acknowledge the Staff’s comment and appreciate the clarification regarding the presentation of segment profitability measures in the MD&A. In response to the Staff’s June 5, 2025 comment, we had proposed including line items for “Corporate, eliminations and other” and “Consolidated Adjusted EBITDA” within our segment Adjusted EBITDA table in the MD&A, in order to reconcile the total of segment results to the consolidated Adjusted EBITDA amounts disclosed on page 38 of the Form 10-K. Based on the Staff’s most recent comment, we understand that using terminology such as “Corporate, eliminations and other” may imply the presentation of a reconciling item consistent with ASC 280-10-50-30, which is required to appear in the footnotes to the financial statements and not within the MD&A. We also understand that including a “Corporate, eliminations and other” row could cause confusion when…

The Golden Chest deposit is generally considered an orogenic gold system. The ore is associated with faults/veins that geologically are relatively continuous. Known cross cutting faults that control mineralization are modeled as such in the geologic model. The ore occurs in shoots that are of varying width near the Idaho fault, as such the Company applies what it considers a conservative definition of measured and indicated resources. 201 N. Third Street Coeur d’Alene, ID 83814, Phone (208) 625-9001, www.idahostrategic.com 3 All of the categories above must also meet the 2 gram per tonne cut off at the diluted minimum mining width. The mineralizing system has been drilled for 1,150 meters on strike and 360 meters down-dip. The Company feels that this illustrates the geologic continuity of the mineralizing structures. Indicated resources are 75% to 80% interpolated with the remainder…

The Company acknowledges the Staff's comment and respectfully notes on a supplemental basis that the reference to a “~26% Return on Equity” reflects an illustrative and hypothetical example of the potential economics arising from an integrated asset management and insurance “flywheel” structure, strategy, and integration. It does not represent a forecast, target, or projection of actual or expected returns of Mount Logan's stock performance, nor an expected return of the Business Combination. The referenced example on page 14 of the “MLC-TURN Executive Summary” investor presentation demonstrates, under a stylized set of assumptions, the potential output from a hypothetical $10 million capital contribution from Mount Logan, the asset manager, into its wholly owned insurance company, Ability, assuming specific parameters for Beijing | Boca Raton | Boston | Chicago | Hong Kong | London |…

The Company advises the Staff that the page numbers referencing 180 Degree Capital's financial statements for the period ending March 31, 2025, have been updated to reflect the correct page references. The Company further advises the Staff on a supplemental basis that it does not believe that 180 Degree Capital, as a registered investment company, is required to include financial statements for the period ending March 31, 2024. Specifically, the financial statements included in the Registration Statement for the period ending March 31, 2025 meet the technical requirement of Item 3-01(e) of Regulation S-X, which requires a balance sheet dated within 135 days of the date of filing. As a registered investment company, however, 180 Degree Capital is not otherwise typically required to prepare or report similar interim quarterly information. Additionally, the financial statements included…

We respectfully advise the Staff that we have revised the disclosures in the table on page 59 of the Amended Registration Statement and throughout the MD&A section of the Amended Registration Statement to present expenses and losses in parenthesis to appropriately reflect them as negative amounts Liquidity and Capital Resources Liquidity, page 55

The CODM, our Chief Executive Officer, uses a single measure of segment profit or loss to assess performance and allocate resources across our reportable segments: Adjusted EBITDA. This measure is provided to the CODM as part of our management reporting package on a recurring basis and forms the basis for decision-making regarding the allocation of resources and performance evaluation. While operating income and net income by segment have been presented in the appendix section of the management reporting package for reconciling purposes, they are not used by the CODM for performance assessment or resource allocation. This schedule has been removed from our management reporting packages in the second quarter. Additionally, operating income and net income by segment are not included in our annual budget package or long-range model projections further supporting they are not used by the…

The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company has removed its disclosure from the MD&A. Instead, the Company has revised its disclosure, which is now included in the Business Securities and Exchange Commission June 27, 2025 Page 3 section on page 130 of the Registration Statement, to clarify what the graphic represents and disclose the material assumptions underlying the projected information and any material factors that may affect such assumptions. Management Board Composition, page 138

As stated in the MD&A on page 16 of the Company’s Form 10-Q for the quarter ended March 31, 2025 (the “Q1 2025 Form 10-Q”), the decline in the Company’s provision for income taxes was primarily due to discrete tax benefits, which is consistent with the change in the effective tax rate for the periods, as presented in the income tax footnote on page 9 of the Q1 2025 Form 10-Q. The Company will clarify this in future filings, to the extent changes in the effective tax rate are material. Form 10-K for the Fiscal Year Ended December 31, 2024 Management’s Discussion and Analysis of Financial Condition and Results of Operations Overview, page 18

The Golden Chest deposit is generally considered an orogenic gold system. The ore is associated with faults/veins that geologically are relatively continuous. Known cross cutting faults that control mineralization are modeled as such in the geologic model. The ore occurs in shoots that are of varying width near the Idaho fault, as such the Company applies what it considers a conservative definition of measured and indicated resources. All of the categories above must also meet the 2 gram per tonne cut off at the diluted minimum mining width. The mineralizing system has been drilled for 1,150 meters on strike and 360 meters down-dip. The Company feels that this illustrates the geologic continuity of the mineralizing structures. Indicated resources are 75% to 80% interpolated with the remainder extrapolated. Measured resources are 90-100% interpolated. The conversion rate of measured and…

We acknowledge the Staff’s comment requesting that we expand our critical accounting estimates disclosure appearing in management’s discussion and analysis of financial condition and results of operations (MD&A) to address those financial statement items that require significant management estimates and judgment pursuant to Item 303(b)(3) of Regulation S-K. In our forthcoming Quarterly Report on Form 10-Q for the second quarter of 2025 (“Q2 Form 10-Q”) and future Form 10-K filings, instead of cross-referencing an enhanced discussion appearing in our financial statement footnotes, we will expand our critical accounting estimates disclosure within MD&A to include qualitative and quantitative information necessary to understand the estimation uncertainty and the impact the critical accounting estimate has had or is reasonably likely to have on our financial condition or results of…

The Company respectfully acknowledges the Staff’s comment and will consider enhancing our tabular disclosures to include the amounts disclosed in non-tabular form and other material sub-components of our three revenue categories in future filings with the Commission. We have historically disaggregated revenue into the categories of transaction income, subscription revenue, and income from other services, as we believe these revenue categories best reflect how we view and manage our business. After consideration of providing further disaggregation by type of customer, we believe that our revenue disaggregation disclosures in the Annual Report meet the requirements of ASC 606-10-50-5 and 55-89 through 55-91; however, in the future we will consider adding additional dimensions of revenue disaggregation in future filings with the Commission if we believe that it would be meaningful to…

We respectfully advise the Staff that we will revise and update the corresponding amounts in the “Unaudited Condensed Consolidated Statements of Income” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations” sections and elsewhere, as applicable, for the unaudited financial statements related to the six months ended December 31, 2024 and 2023, which will be included in our next amendment to the registration statement on Form F-1. We thank the Staff for its review of the foregoing. If you have any further comments or questions, please feel free to contact to our counsel, Wei Wang, at wwang@egsllp.com or by telephone at (212) 370-1300. Sincerely, /s/ Jinchun Cheng Jinchun Cheng, Chief Executive Officer cc: Wei Wang, Esq. Ellenoff Grossman & Schole LLP

The Registrants respectfully acknowledge the Staff’s comment and respectfully advise the Staff that individual sources of digital services revenue included within the mobile telecommunications services offered and referenced in the Staff’s comment were not material for the years ended December 31, 2024 and 2023 (digital services only represented 2.3% and 1.2% of total combined revenues, respectively). The Registrants will continue to monitor the materiality of the various mobile telecommunications sources of revenue, as well as other qualitative factors, to determine whether the information becomes material for the users of the Registrants’ financial statements, including whether the revenues for these categories should be disaggregated. If the individual sources of revenue for mobile telecommunication services are deemed material, the Registrants will revise their future filings to…

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it will enhance the discussion of all material changes in the statement of operations line items on a consolidated basis. Further, we will discuss the business as a whole and provide segment information as necessary for an understanding of our business. The Company will incorporate discussion in the Form 10-Q for the quarter ending June 30, 2025, and future filings in response to the Staff’s comment. Non-GAAP Financial Measures, page 39

Historically, our company operated as one operating segment. Because all of our brands had similar economic characteristics; products; production processes; types or classes of customers; distribution methods; and regulatory environment, we did not believe grouping our brands for purposes of FASB ASC 280-10-50-38 and 40 would provide meaningful information for our investors or analysts. Therefore, in response to a prior comment letter from the Staff and to comply with the guidance in FASB ASC 280-10-50-38 and 40, instead of disclosing net sales by groups of brands we began disclosing in 2014 in a footnote to our financial statements net sales by individual brand for all of our brands that exceeded a certain minimum net sales threshold (typically, 3%) and then aggregated net sales for the remaining brands. Following our recent reorganization into four reportable segments, we reassessed…

In future filings, we will add the following sentence to the end of our first paragraph in the Rental Property Revenues, Rental Property Operating Expenses, and Net Operating Income section of Item 7, Management's Discussion and Analysis of Financial Condition and Results of Operations. “We consider many factors in determining whether a property has stabilized, including the property’s occupancy (independently and relative to its submarket) and current leasing pipeline, as well as time since the cessation of major construction activity.” May 22, 2025 Page 3 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 29 3.

In response to the comment, we have expanded the disclosures contained under the heading “Operating Costs” beginning on page 49 of the prospectus contained in Amendment No. 9, as well as in the table contained in Note 28 of the financial statements included in Amendment No. 9, to report a measure of profit or loss for Empro Group’s two reportable segments. When evaluating the revised disclosures, please note that for internal management reporting purposes, the Chief Executive Officer and Chairman of the Board of Directors, who serves as the chief operating decision maker, evaluates the operating performance of each business segment solely based on gross profit. If you have any further questions or comments, or would like to discuss this response letter, please feel free to call the undersigned at (212) 326-0468 or to email the undersigned at mcampoli@pryorcashman.com . Sincerely, /s/…

In response to the comment, we have expanded the disclosures contained under the heading “Operating Costs” beginning on page 49 of the prospectus contained in Amendment No. 8, as well as in the table contained in Note 28 of the financial statements included in Amendment No. 8, to report a measure of profit or loss for Empro Group’s two reportable segments. If you have any further questions or comments, or would like to discuss this response letter, please feel free to call the undersigned at (212) 326-0468 or to email the undersigned at mcampoli@pryorcashman.com . Sincerely, Michael T. Campoli Michael T. Campoli Pryor Cashman LLP cc: Yeoh Chee Wei

We respectfully acknowledge the Staff’s comment and confirm that we will revise our presentation of segment adjusted EBITDA to remove the subtotal “total reportable segments’ adjusted EBITDA” and the line item “Corporate and other”, as reflected below, from our MD&A in future filings beginning with our Form 10-Q for the period ending June 30, 2025 as well as our future Form 8-K earnings releases. Segment Analysis Percent favorable Year ended December 31, (unfavorable) (Dollars in millions) 2024 2023 change Huntsman Corporation Segment adjusted EBITDA (1) Polyurethanes $ 245 $ 248 (1 )% Performance Products 153 201 (24 )% Advanced Materials 179 186 (4 )% Huntsman International Segment adjusted EBITDA (1) Polyurethanes $ 245 $ 248 (1 )% Performance Products 153 201 (24 )% Advanced Materials 179 186 (4 )% (1) For more information regarding reconciliations of segment adjusted EBITDA of our…

The Company acknowledges the Staff’s Comment and responds as follows: • The contracted operator is compensated through a services arrangement that entitles them to retain an agreed portion of gross proceeds, net of equipment usage fees and shared costs. These amounts are classified as selling and marketing expenses. All other direct production costs are reported as cost of goods sold. • The Company has updated its disclosure on page 25 of Amendment No. 2 and in Note 6 to the financial statements to update the terms of the subscontractor agreement; and May 15, 2025 Page 8 • In arriving at that the determination that we are the principal pursuant to ASC 606- 10-55-36 through 55-40, we undertook the following analysis: The Company maintains ownership and control of the facility, assets, and customer relationships. Revenue from customer contracts is recognized by the Company in accordance…

In response to the Staff’s comment, Aebi Schmidt has revised the disclosure on page 177 to clarify the description of key performance measures presented in or derived from Aebi Schmidt’s GAAP financial statements. These measures are not internally-derived metrics that are potentially subject to adjustment. In addition, Aebi Schmidt has removed reference to any challenges in measuring usage and engagement. Results of Operations, page 175

The Company respectfully acknowledges the Staff’s comment, and informs the Staff that in future filings the Company will provide additional detail on these matters, including the 2024 Form 10-K, related to (a) trading losses in our proprietary trading accounts recognized in the Capital Markets segment in 2024 and (b) disclosure and comments on the quality of, and potential variability of revenue, earnings and cash flows generated. General

The Company respectfully advises the Staff that the CODM, its president and Chief Executive Officer, evaluates the performance of operating segments based on revenues and two measures of segment profit: (1) segment gross profit and (2) segment income from operations. Segment gross profit and segment income from operations are both measures of segment profit that the CODM uses to assess segment performance and allocate resources. The CODM reviews budget and actual revenues, gross profits, and income from operations of the operating segments and decides how to allocate resources to meet our strategic priorities. Generally, the Company uses the same accounting principles in the preparation of the segment information as those used for the consolidated financial statements. However, segment income from operations does not include foreign currency transaction gains and losses. 1 We regularly…

We respectfully acknowledge the Staff’s comment and advise the Staff that the Company’s long-term capital allocation plan is designed to invest in accretive organic growth, subject to disciplined capital investment parameters. Final investment decisions (“ FID ”) on growth projects contemplate a project’s technical and economic viability, including consideration to the receipt of necessary authorizations and permits; the anticipated availability of liquidity and capital resources to construct, commission, and operate the project; technical feasibility and risk-based assessment of the project; and financial viability of the project based on securing the necessary commercial contracts to underpin investment and long-term value creation for our shareholders and other stakeholders. FID is ultimately overseen by our Board of Directors to ensure decisions align with the Company's strategic…

The Amendment includes the audited financial statements for the fiscal year ending December 31, 2024 for each of the Company and Fusemachines Inc. Accordingly, the MD&A and Subsequent Events footnotes have been revised to disclose significant events that occurred up to the date of the Amendment. Please contact Alexandria Kane at (212) 407-4017 or myself at (212) 407-4043 with any questions. Sincerely, /s/ Julia Aryeh Julia Aryeh Senior Counsel cc: Alexandria Kane