Fair value

We respectfully acknowledge the Staff’s comment. • Confirm that you will disclose prior year comparative information; We confirm that we have provided prior year comparative information related to adjusted diluted net loss per share for our most recently filed earnings release for the period ended September 30, 2025, furnished with the Commission on October 27, 2025 under Item 2.02 of our Current Report on Form 8-K (the “ Q3 2025 Earnings Release ”), and will continue to do so in future filings. • Confirm that you will disclose, at a similar level as you provided in your response letter dated September 18, 2025, the reasons why management believes that adjusting for income/loss relating to equity method securities and the gain/loss on debt securities carried at fair value in arriving at adjusted diluted net loss per share provides useful information to investors; and We respectfully…

The Fund employs a robust process to estimate the fair value of its investments at the end of each financial quarter. Please refer to the following excerpt from Part II, Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations — Critical Accounting Estimates: Fair value is based on observable market prices or parameters or derived from such prices or parameters when such quotations are readily available. In accordance with Rule 2a -5 under the 1940 Act, a market quotation is “readily available” only when it is a quoted price (unadjusted) in active markets for identical instruments that a fund can access at the measurement date, provided that such a quotation is not considered to be readily available if it is not reliable. The Company utilizes mid -market pricing (i.e., mid -point of average bid and ask prices) to value these investments. These market…

The Fund hereby confirms that it will make the requested change in future filings. 6. Disclosure in “Note

The Registrant did not include a range or weighted average of significant unobservable inputs in the Annual Report because each row in the relevant table for which an input was provided pertains to a single investment using that particular unobservable input. As such, no range or weighted average was relevant to the fair value measurements disclosed. The Registrant will seek to clarify the presentation of this table in future filings. - 3 - October 23, 2025 5.

In response to the Staff’s comment, the Company has revised throughout Amendment No.1 to treat the holders of the NextG Tech Convertible Debts as the Reorganization Shareholders, as the holders have elected to convert the loans into CH-AUTO Tech’s shares prior to the Reorganization. Accordingly, the Pubco Ordinary Shares to be issued to Reorganization Shareholders has been revised to 89,904,646 instead of 89,023,050 as reflected in the pro forma financial statements and related Company share information. The Company has also revised the disclosure on page 216 to add a pro forma transaction adjustment regarding above debt conversion. Summary of the Proxy Statement/Prospectus IPO Underwriting Agreement, page 142

The Company respectfully clarifies that: ● After considering the conversion of the NextG Tech Convertible Debts into the CH-AUTO Tech’s shares prior to the Reorganization, the percentage of CH-AUTO Tech’s shareholdings participating in the Reorganization has been increased to 71.9237% from 71.2184%. As of the date of submission, it is the most updated resolution for the Reorganization based on all factual supporting events such as the approval of CH-AUTO Tech’s shareholders meeting. Therefore, pro forma financial statements present the three scenarios of redemption of MCAF’s shareholders based on this result of the Reorganization. Further, as there is an uncertainty regarding whether all or a portion of the Company’s shares under pledge or judicial freezing will be exercised or auctioned off before the closing of the Reorganization, the Company has revised the disclosure on page 208-212…

Term and conditions of put and call arrangements: The time frames for the exercise of the put and call arrangements are disclosed in footnote 11 starting on page F-36. There are no conditions which change the time frames of the put or call exercise for the 3 Arts Entertainment noncontrolling interest. In the second paragraph under the 3 Arts Entertainment section on page F-36, there is a discussion indicating that if the noncontrolling interest holder's employment terminates, their participation in the put or call price could be a discount to fair value, however, the actual exercise of the put and call is not accelerated. With respect to the Pilgrim Media Group noncontrolling interest put and call, the only condition which could accelerate the Pilgrim Media Group put and call option exercise is if the noncontrolling interest holder were to terminate his employment, which would result in…

In accordance with ASC 606-10-32-25A, the Company measured the warrants using ASC 718. In accordance with ASC 718-10-20 guidance, the grant date was determined to be December 28, 2021, which was the date that satisfied the definition of grant date based on the following factors: a. Credo and Amazon reached a mutual understanding of key terms and conditions upon signing of the agreement on December 28, 2021; b. On December 28, 2021, Credo became contingently obligated to issue Credo’s ordinary shares to Amazon based on purchase of goods or services as a customer; c. Approval by Credo’s board of directors was obtained on December 15, 2021 (prior to the signing of the agreement); and d. Amazon began to benefit from or to be adversely affected by a change in Credo’s share price once the exercise price of the warrants was set at $10.74 on December 28, 2021 (the date of the signing of the…

For further clarification, MRC’s put option relates solely to MRC’s 10% ownership of CAM Common Interests. It has no relation to, or impact on, MRC’s approximate $45 million commitment to the Investment Interests of CAM. Regarding the accounting treatment of this put option, the Company considered the guidance under FASB ASC 815-10 and determined that this option should not be accounted for as a derivative, because: • If exercised, MRC would be giving control of CAM to Air T, which would result in the Company obtaining a controlling financial interest in CAM; • It cannot be settled net. On each of the first three anniversaries of CAM's closing date (the “Option Period”), MRC has the right to put to the Company all of its Common Interests for a purchase price of $1 million. Therefore, the Company’s maximum exposure to loss under this put option could only be $1 million (if the value of…

The Funds acknowledge the Staff’s comment and respectfully note that the Financial Statements for Goldman Sachs Financial Square Federal Instruments Fund, Goldman Sachs Financial Square Government Fund, Goldman Sachs Financial Square Money Market Fund, Goldman Sachs Financial Square Prime Obligations Fund, Goldman Sachs Financial Square Treasury Instruments Fund, Goldman Sachs Financial Square Treasury Obligations Fund, and Goldman Sachs Financial Square Treasury Solutions Fund indicate, in relevant part, that “[a]ll investments for the Institutional Money Market Funds are classified as Level 2, with the exception of treasury securities of G7 countries which are generally classified as Level 1” (emphasis added). The “Institutional Money Market Funds” are defined to include only the Goldman Sachs Financial Square Money Market Fund and Goldman Sachs Financial Square Prime Obligations…

As stated in the terms of our service contract with the pool operator, we are able to continuously determine if we will provide hash rate or not provide hash rate without penalty (response to second bullet of question 10). The moment to moment decision to provide hash rate to the pool operator is considered to be contract inception and the performance obligation is satisfied when the hash rate processing power is provided. Per ASC 606-10-32-5, we estimate the most likely amount (in accordance with ASC 606-10-32-8b) to which the entity will be entitled through the use of a third-party software tool that precisely tracks the computing power we provide to the mining pool operator and estimates the revenue generated from total hash expected to be contributed, and on current market conditions (block payout metrics) during a successful block attempt (how much our reward may be impacted by the…

We will revise our accounting to comply with ASC 350-30-35-19 and conform our disclosure related to digital currency fair value impairment testing. We will remove the reference to a “nightly” measurement when determining fair value for impairment testing and instead reference Bitcoin intraday lows as the measurement used for fair value testing. 8. Digital Currencies, page F-30 Comment No.

The Company acknowledges the Staff’s comment and respectfully submits that the Company has analyzed the revenue requirements under ASC 606 as follows: Step 1 of ASC 606 The Company noted the following requirements pursuant to ASC 606-10-25-1: “An entity shall account for a contract with a customer that is within the scope of this Topic only when all of the following criteria are met: a) The parties to the contract have approved the contract (in writing, orally, or in accordance with other customary business practices) and are committed to perform their respective obligations. b) The entity can identify each party’s rights regarding the goods or services to be transferred. c) The entity can identify the payment terms for the goods or services to be transferred. d) The contract has commercial substance (that is, the risk, timing, or amount of the entity’s future cash flows is expected to…

The Fund counts derivatives towards satisfaction of the 80% test in a manner consistent with the Commission’s statement that, “[i]n appropriate circumstances .... an investment company [would be permitted] to include a synthetic instrument in the 80% basket if it has economic characteristics similar to the securities included in that basket.” (Investment Company Act Release No. 24828 (January 17, 2001).

Comment: Tell us why you have not presented for the predecessor the combined balances of the twenty entities that you have identified as comprising the predecessor operations at the dates that each was conveyed and or derecognized by Golar LNG Limited; and why you have not presented for the successor the equity balances as of the beginning of the year and separate lines for the financing and investing transactions that occurred and impacted the equity balances during the interim period. In response to the Staff’s comment, the Company notes that as described in Note 1 of the interim financial statements on pages F-39 and F-40 and pursuant to the Vessel SPA and ManCo SPA, CoolCo acquired thirteen legal entities from Golar on various acquisition dates during the period from March 3, 2022 to June 30, 2022. As further described in the following paragraph, the Company has revised the…

In response to the Staff’s comment, the Company has revised footnote 2 in Note 12 on page F-56 of the Registration Statement to note that the depreciation and amortization reflects the impact of remeasurement to fair value of the LNGCs acquired pursuant to the Vessel SPA. This update indicates that the depreciation charged during the Predecessor period of $5,745 thousand is depreciation charged by the Predecessor based on the net book value of the Original Vessels before the revaluation of such vessels and as per the respective accounting policy of the Predecessor as noted in Note 2d on page F-50 of the Registration Statement. Depreciation charged during the Successor Period is based on the revised fair value of such vessels upon acquisition by the Company as described under the vessels and equipment accounting policy disclosed in Note 2c. As explained above, the Company believes that…

In response to the Staff’s comment, the Company has revised its disclosures in Note 1 on page F-41 of the Registration Statement, to include a tabular presentation of the Predecessor combined carve-out account balances derecognized upon disposal and also reflect the aggregate assets and liabilities that were specifically identifiable and directly attributable to the entities, acquired pursuant to the Vessel SPA on various dates from March 3, 2022 to April 5, 2022 and the four management entities, acquired pursuant to transactions under the ManCo SPA which closed on June 30, 2022. The table further presents the fair value and other adjustments to all the assets and liabilities balance acquired and the allocation of excess purchase consideration to such balances based upon relative fair values as determined and recognized upon acquisition by the Successor. U.S. Securities and Exchange…

The Company has revised its disclosure to include fair values of its portfolio companies as of September 30, 2022.

In response to the Staff’s comment, the Company has revised the disclosures regarding Critical Accounting Policies and Estimates on page 219 of the Amended Registration Statement to add goodwill impairment as a critical accounting estimate. The Company respectfully advises the Staff that Tranglo represents a separate reporting unit, and impairment testing of the goodwill arising from the acquisition of Tranglo includes only Tranglo operations. Results of Operations, page 220

Page 108 have been revise to disclose the valuation of the LBX Tokens in accordance with the Staff’s comment. The LBX Tokens are recorded at a valuation of 0 on Royalty’s financial statements. Information About American Acquisition Opportunity Directors and Executive Officers, page 114

The “Change in fair value of life insurance policies (policies held using fair value method)” in the income statement includes realized and unrealized gains/(losses) on policies. Only the unrealized gains/(loss) of $3,957,809 should be an added back to net income as a non-cash operating item with the realized gain and premiums expense flowing through net income. This amount is calculated as the change in fair value from the Income Statement of $3,801,031, plus the premiums paid of $261,778 (to remove the impact of the included premiums expense), minus the realized gain of $105,000 related to matured policies and agrees to the fair value rollforward on page F-93, which we have expanded for additional clarity. We have revised the presentation and naming of the statement of cash flow line item in the Amended Proxy Statement on page F-83. ********** Any comments or questions regarding the…

Consistent with prior comments from the Staff, the Funds will use the notional value of derivatives instruments for purposes of complying with Rule 35d-1. In addition to prior Staff comments, the Trust points to the recently issued proposing release seeking to amend Rule 35d-1 to codify this position. The proposing release states, in part, that “…in calculating its assets for purposes of names rule compliance, a fund must value each derivatives instrument using its notional amount . . . .” The proposing release goes on to say the “names rule is designed to ensure that a fund’s investment activity supports the investment focus its name communicates, and for funds that use derivatives instruments, the investment exposure of those derivatives instruments is generally better reflected by a derivatives instrument’s notional amount than by its market value.”

The disclosure on page 323 has been updated in response to the Staff’s comment. Beneficial Ownership of Securities, page 358

The Company respectfully acknowledges the Staff’s comment. The Company uses the Black-Scholes-Merton option-pricing model to calculate the fair value of stock options granted. Inputs into this option-pricing model include the exercise price of the option, the expected term of the option, the current price of the underlying share, the expected volatility of the price of the underlying share, the expected dividends on the underlying share, and the risk-free interest rate for the expected term of the option. The Company generally begins its estimation of the expected volatility rate by analyzing historical realized volatility. ASC 718-10-55-37(a) indicates that historical realized volatility should be measured over a period commensurate with the expected term of the option. While the Company’s shares have been publicly traded since July 2018, the length of time its shares have been…

LMA determined to account for certain policies following the investment method, pursuant to ASC 325-30-25-2, which permits an instrument-by-instrument election of approach supported by concurrent documentation. This election was made in June 2022, which was the result of a cost-benefit analysis. Because of management’s intention to hold the instruments for a relatively short period, management believed that the investment method provided a more cost effective method of accounting for the instruments and did not believe that, in the course of the short period, the fair value would differ materially from the accumulated cost. Beginning in 2024, LMA has made the determination to measure all new policies acquired under the fair value method going forward and intends to sell all of its policies currently accounted for under the investment method in the next three to six months. LMA will…

LMA accounted for these policies following the fair value method, pursuant to ASC 325-30-25-2, which permits an instrument-by-instrument election of approach supported by concurrent documentation. For the life settlement policies accounted for under the fair value method, these policies are part of the collateral consideration for the market linked structured notes issued under LMATT subsidiaries where quarterly valuations are a condition of the private placement memorandum. Given that there is a valuation requirement stipulated in the private placement memorandum of the structured note offerings, management has elected to use the fair value method for these policies as the information is readily available and also captures the change in fair value within the income statement when those changes occur as opposed to when the policies mature given management’s intention to hold them to…

Premiums paid and life insurance proceeds received related to policies accounted for pursuant to the fair value method have been captured in the ‘Change in fair value of life insurance policies (policies held using fair value method)’ line of the Statement of Operations and Comprehensive income in accordance with ASC 325-30-45-4. LMA has revised the Life Insurance Settlement Policies disclosure on page F-87 of the Amended Proxy Statement to state: “For policies held at fair value, changes in fair value, premiums paid and life insurance proceeds received are reflected in change in fair value of life insurance policies (policies held using fair value method) in the period the change is calculated.” Note 10. Fair Value Measurements, page F-93

When premiums are paid on policies accounted for under the fair value method, the journal entry is as follows: • Dr. Life settlement policies- at fair value • Cr. Cash When life settlement policies are valued at the end of each quarter, LMA adjusts for the policy value and change in fair value as follows: • Dr. Life settlement policies- at fair value • Cr. Change in fair value of life insurance policies (policies held using fair value method) These journal entries appropriately capture the change in fair value of the policy, and the effect of premiums expense being debited to the same financial reporting line as changes in fair value in accordance with ASC 325-30-45-4. As the payment of premiums is originally recorded to the life settlement policy, management included premiums paid in the original value of policies purchased in the rollforward. As the change in fair value is then…

The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on page 110 to state that the Registrant recognized a gain of $5.2 million for the nine months ended September 30, 2021, related to changes in fair value for the 2022, 2021 and 2020 convertible notes. VIA EDGAR Page 3 Executive Compensation, page 153

Ferret and WSL purchased the shares of Worldcall Telecom Limited from OmanTel, the national telecom company of Oman. At the time, the Worldcall fiber network was approximately 1800 km, we estimated the replacement cost of the fiber network at approximately $40 million as the cost was about $42,000 per mile. Our purchase price was substantially lower. Based upon the fiber infrastructure we assumed that going forward this infrastructure will be used for long-haul traffic connecting various cities we operate and increasing our offerings this is similar to cable companies in the United States such as Comcast which owns its own fiber network to transmit it’s Data and video to its various markets. Division of Corporation Finance January 6, 2023 Page 10 of 11

Rule 2a-5(d) provides, in part, “[i]f the fund is a unit investment trust . . . the fund’s trustee or depositor must carry out the requirements of paragraph (a) of this section.” The Trust notes that First Trust Portfolios L.P. is the Trust’s “Sponsor,” which is the term used in the Registration Statement to refer to the depositor. The Trust respectfully points the Staff to the cover page of the S-6 filing, which states that the name of the depositor is First Trust Portfolios L.P. The Trust confirms the disclosure throughout the Registration Statement is consistent with Rule 2a-5. Portfolio

Rule 2a-5(d) provides, in part, “[i]f the fund is a unit investment trust . . . the fund’s trustee or depositor must carry out the requirements of paragraph (a) of this section.” The Trusts note that First Trust Portfolios L.P. is each Trust’s “Sponsor,” which is the term used in the Registration Statement to refer to the depositor. The Trusts respectfully point the Staff to the cover page of the S-6 filing, which states that the name of the depositor is First Trust Portfolios L.P. The Trusts confirm the disclosure throughout the Registration Statement is consistent with Rule 2a-5. Portfolio

Rule 2a-5(d) provides, in part, “[i]f the fund is a unit investment trust . . . the fund’s trustee or depositor must carry out the requirements of paragraph (a) of this section.” The Trust notes that First Trust Portfolios L.P. is the Trust’s “Sponsor,” which is the term used in the Registration Statement to refer to the depositor. The Trust respectfully points the Staff to the cover page of the S-6 filing, which states that the name of the depositor is First Trust Portfolios L.P. The Trust confirms the disclosure throughout the Registration Statement is consistent with Rule 2a-5. Risk Factors

Rule 2a-5(d) provides, in part, “[i]f the fund is a unit investment trust . . . the fund’s trustee or depositor must carry out the requirements of paragraph (a) of this section.” The Trust notes that First Trust Portfolios L.P. is the Trust’s “Sponsor,” which is the term used in the Registration Statement to refer to the depositor. The Trust respectfully points the Staff to the cover page of the S-6 filing, which states that the name of the depositor is First Trust Portfolios L.P. The Trust confirms the disclosure throughout the Registration Statement is consistent with Rule 2a-5. Portfolio

Rule 2a-5(d) provides, in part, “[i]f the fund is a unit investment trust . . . the fund’s trustee or depositor must carry out the requirements of paragraph (a) of this section.” The Trust notes that First Trust Portfolios L.P. is the Trust’s “Sponsor,” which is the term used in the Registration Statement to refer to the depositor. The Trust respectfully points the Staff to the cover page of the S-6 filing, which states that the name of the depositor is First Trust Portfolios L.P. The Trust confirms the disclosure throughout the Registration Statement is consistent with Rule 2a-5. Portfolio

The Company respectfully acknowledges the Staff’s comment and believes that its adjustments to eliminate losses (gains) on marketable equity securities and net interest expense related to fair value adjustments of the mandatorily redeemable noncontrolling interest do not substitute individually tailored recognition and measurement methods that violate Rule 100(b) of Regulation G and thus is not prohibited under the Staff’s guidance in Question 100.04 of the Division of Corporation Finance’s Non-GAAP Financial Measures Compliance and Disclosure Interpretations (“CDI 100.04”). The Company believes the adjusted net income, after taking into account these adjustments, does not contain an untrue statement of material fact; nor does it omit to state a material fact that would make the presentation of the adjusted net income misleading when taken together with the information accompanying…