Segment reporting

The Company advises the Staff that the disclosure on pages F-57, F-58, F-94, and F-95 of the Registration Statement has been revised to disclose capital expenditures by segment for each period presented. Unaudited Consolidated Financial Statements Note 6 - Intangible Assets and Goodwill, page F-73

The Company acknowledges the Staff’s comment and notes that the AI segment has two reporting units: X reporting unit which is comprised of the former X business; and xAI reporting unit which is comprised of the former xAI business (excluding former X business). Substantially all of the goodwill attributable to the Company's AI segment is attributable to the X reporting unit. For the period ended March 31, 2026, the Company assessed if there are any events or circumstances that could more likely than not reduce the fair value of the X and xAI reporting units in the AI segment below its carrying amount. As clarified on pages 12, 16, 53, and 54 of the Registration Statement, although there could be certain risks with an acquisition and integration of an early stage company such as xAI, no triggering events have occurred during the three months ended March 31, 2026 that indicated the…

Management views the Company as a single segment managed on a consolidated basis and will include the following in Note 1 of the Notes to Consolidated Financial Statements in future filings, beginning with the Company’s Quarterly Report on Form 10-Q for the quarter ending June 30, 2026: “The Company reports segment information in accordance with ASC Topic 280, Segment Information (“ASC 280”). ASC 280 requires companies to report financial and descriptive information for each identified operating segment based on management’s internal organizational decision-making structure. Management has determined that the Company has one single reportable segment based on its method of internal reporting in addition to its allocation of capital and resources. The primary focus of our business is the ownership and operation of our manufactured home communities – leasing of manufactured homesites and…

Applicable disclosure regarding the ASU will be included in future reports. * * * * * Should the Staff have any further comments or questions, please contact me at (212) 905-9106 or by e-mail at george.silfen@alston.com. Thank you for your attention to this matter. Very truly yours, /s/ George M. Silfen 2

The Fund will make the requested change in future reports. Please call me (202-636-5806) with any questions you may have regarding this filing or if you wish to discuss the above responses. Sincerely, /s/ Ryan P. Brizek Ryan P. Brizek cc: Christopher Cilenti, J.P. Morgan Investment Management Inc. Carmine Lekstutis, Esq., J.P. Morgan Investment Management Inc. Henry Pickell, Esq., J.P. Morgan Investment Management Inc. Rajib Chanda, Esq., Simpson Thacher & Bartlett LLP Neesa Patel Sood, Esq., Simpson Thacher & Bartlett LLP David Howe, Esq., Simpson Thacher & Bartlett LLP 2

The Company respectfully advises the Staff that it carefully considered the disclosure requirements of ASC 280-10-50-22, 50-25, 50-26 and 50-30(c) in preparing the segment disclosures in Note 20 of the Form 10-K. As described below, the Company concluded that disclosure of total assets by reportable segment was not required because asset information is not included in the financial information regularly provided to the Company’s chief operating decision maker (“CODM”) for purposes of assessing segment performance or making resource allocation decisions. ​ ​ 4747 Bethesda Avenue, Suite 200, Bethesda, Maryland 20814 240.333.3600 jbgsmith.com ​ As disclosed in Note 20 of the Form 10-K, the Company’s CODM is its Chief Executive Officer. The Company has three reportable segments: multifamily, commercial, and third-party real estate services. The CODM measures and evaluates the performance of…

The Company respectfully acknowledges the Staff’s comment regarding the level of revenue disaggregation. The Company’s current disclosures include revenues from external customers and intersegment revenues for each reportable segment in accordance with ASC 280-10-50-22, as well as revenues by geographic area in accordance with ASC 280-10-50-41. The Company also considered the requirements of ASC 280-10-50-40, which requires disclosure of revenues for each product and service, or each group of similar products and services. In applying this guidance, the Company evaluated whether its product and service offerings represent distinct groupings with materially different characteristics and also considered the illustrative guidance in ASC 606-10-55-89 through 55-91 in determining the appropriate level of disaggregation. This assessment included both qualitative and quantitative factors,…

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…

As noted in our footnote 10, Business Segment Information, we stated that Corporate is not a reportable segment, but it is included for reconciliation purposes. This is to help the reader reconcile our segment disclosures back to our consolidated statements of operations and balance sheets. In future filings, we will present the segment information in a different manner to reconcile to the consolidated totals, as outlined in Exhibit 1. If you have any questions or if you require additional information, please do not hesitate to contact me by phone at 314-213-7245 or email at ctucker@escotechnologies.com Sincerely, Christopher L. Tucker Senior Vice President & Chief Financial Officer ESCO Technologies Inc. 3 Exhibit 1 ESCO TECHNOLOGIES INC. AND SUBSIDIARIES Business Segment Information (in thousands) For Reference - FY 25 Business Segment Disclosures Only FY 25 A&D USG Test Segment Total…

The Registrants have revised the applicable disclosure to name the titles of the persons at the Adviser that comprise the group acting as the CODM. The revised disclosure is below (underlined language added): “Subject to the oversight and, when applicable, approval of the Board of Trustees, portfolio managers and senior executives at the Adviser act as the Trust’s chief operating decision maker (“CODM”), assessing performance and making decisions about resource allocation within the Trust.” 2.

In response to the Staff’s comment, the Company intends to include in its future applicable filings a description of the types of adjustments applied to our significant segment expenses for each reportable segment. Additionally, the Company will disclose in greater detail with quantification the specific types of material amounts included in Total Corporate Expenses within Adjusted EBIT in an appropriate manner taking into consideration the nature and quantity of such amounts. Please contact me at rduvivier@krispykreme.com if you have any questions or additional comments. Sincerely, /s/ Raphael Duvivier Raphael Duvivier Chief Financial Officer Krispy Kreme, Inc. cc: Brian V. Breheny, Skadden, Arps, Slate, Meagher & Flom LLP

Under ASC 280-10-50-5, the CODM is identified as a function, not necessarily a specific individual or title. This function is responsible for allocating resources and assessing performance. While in some organizations this role may be carried out by a single officer, the guidance acknowledges that it can also be a shared function performed by a group. For our Fund, these responsibilities are executed collectively by the Adviser pursuant to the investment advisory agreement between the Fund and the Adviser. The Adviser’s personnel, inclusive of the portfolio management team with input from compliance, legal and product, allocate the resources of the Fund through, for example, determining the composition of the Fund’s portfolio, identifying investment opportunities, and making investment decisions. These individuals assess performance by monitoring the Fund’s investments and regular…

The Company respectfully acknowledges the Staff’s comment and explains that while segment Gross profit (loss) is included in the financial information that is provided to the CODM for informational purposes, the CODM does not use segment Gross profit (loss) when assessing performance and allocating resources. The CODM uses the segment Operating income (loss) to allocate resources and assess performance. Therefore, the Company believes it is the metric required to be disclosed under the guidance in ASC 280-10-50-28A. In future filings, the Company plans to present only this required measure. To address the Staff’s comment and limit confusion on the metric used by the CODM in future filings, the Company will revise Note (17) to remove segment Gross profit (loss) and replace with Cost of Goods Sold and clarify that segment Operating income (loss) is the measure used by the CODM to assess…

The Company respectfully acknowledges the Staff’s comment and confirms that the only segment expense information regularly provided to the CODM is segment Selling, general and administrative expenses. However, as both segment Net sales and segment Gross profit (loss) are also regularly provided to the CODM, segment Cost of sales is significant and easily computable from information regularly provided to the CODM. In future filings, the Company will include disclosure of segment Cost of sales in accordance with the guidance in ASC 280-10-50-26A and 55-15B. Please see the response to Comment 4 below for an illustrative example of future planned disclosures. Further, in accordance with guidance in ASC 280-10-50-26B, the Company proposes to include the following qualitative disclosure of other segment items in addition to quantitative disclosure in the reconciliation of segment profit/loss…

The Company respectfully acknowledges the Staff’s comment and confirms that in future filings it will remove from Note 1 the disclosure regarding Non-GAAP Financial Measures. Additionally, in future filings, the Company will remove the measure of total Adjusted EBITDA from the segment disclosure in Note 20. Please refer to Exhibit 2 for an example of the revised disclosure for the fiscal years ended January 3, 2025, December 29, 2023, and December 30, 2022. Note 20. Segment Information, page 112

The Company respectfully acknowledges the Staff’s comment and confirms that in future filings the Company will remove the line item for unallocated corporate expenses and the total for the amounts of other segment items. In addition, in future filings, the Company will revise and expand its disclosure in Note 20 to state that the chief operating decision maker reviews expenses on a consolidated basis and that no segment level expense information is regularly provided to the chief operating decision maker. The Company will also relocate from Note 1 to Note 20 its existing disclosure that describes how the chief operating decision maker uses segment Adjusted EBITDA to assess segment performance and allocate resources. Please refer to Exhibit 3 for an example of the revised table and revised disclosure. *** We hope that you will find the Company’s response to the Comment Letter…

We respectfully acknowledge the Staff’s comment. The Company acknowledges that its segment footnote refers to Operating Income (Loss) as a metric shared with its Chief Operating Decision Maker (“ CODM ”). The Company currently has one reportable segment, which is its Retail business. The Retail segment comprises the Company’s Bed Bath & Beyond operating segment and Overstock.com operating segment, which are aggregated into a single reportable segment due to their similar economic characteristics and business activities. The Bed Bath & Beyond operating segment includes results from its buybuy BABY brand, and formerly also included the Zulily brand, which was sold in the first quarter of 2025, neither of which are material to the Company’s business. The Retail segment derives revenue primarily from e-commerce sales of home furnishing merchandise through the Company’s suite of websites and…

In response to the Staff’s comment, the Company has revised the disclosure on page F-38 to clearly identify the specific measure of segment profit or loss used by the CODM in assessing performance and allocating resources, as required by ASC 280-10-50-22. The Company has also revised the disclosure on page F-38 to quantify the other segment items reviewed by the CODM and to provide a brief qualitative description of what those items include, consistent with ASC 280-10-50-26B. 2 Amendment No. 3 to Draft Registration Statement on Form S-1 Certain Relationships and Related Party Transactions, page 86

The Trust notes that ASU 2023-07 provides that a fund shall disclose “the title and position of the individual or the name of the group or committee identified” as the CODM. Accordingly, the Trust believes that the current disclosure, identifying the Adviser as CODM, conforms to the requirements of ASU 2023-07 and is consistent with standard industry practice. However, the Trust undertakes to consider disclosing additional information about the individuals fulfilling the CODM role for the Adviser in future financial statements filed with the SEC.

The Company acknowledges the Staff’s comment and respectfully advises the Staff that, as further explained below, the Company determined it has one operating segment and reportable segment. The Company notes that no discrete GAAP or non-GAAP financial measures are available or reviewed by management on any basis other than the consolidated level. The Company does use Annual Recurring Revenue (“ARR”), which is an operational measure, and other analytical, non-financial information that is produced on a disaggregated per product level, such as number of accounts per product. ARR is used by the Company as a growth operational measure and reviewed by the Company’s Chief Operating Decision Makers (“CODMs”) for that purpose only. ARR is an operational measure that is not directly comparable to GAAP revenue. Furthermore, the Company carefully considered all of the relevant factors in ASC…

In response to the Staff’s comment, in future filings we will align our Segments footnote to the presentation as described above for all periods presented. An illustrative example of this presentation is included in the Exhibit attached hereto. Should you have any questions or comments regarding the responses in this letter, please feel free to contact me at (313) 407-3260. Very Truly Yours, /s/ Christopher T. Hatto Christopher T. Hatto Vice President, Global Business Solutions and Chief Accounting Officer 2 Exhibit: Revised Segment Footnote Table - For illustration purposes, we present below a revised version of the table summarizing key financial information by segment, as of and for the year ended December 31, 2024, as presented in Note 23 of the Notes to Consolidated Financial Statements in the 2024 10-K. In particular, in future filings we would add a new column to present a…

In response to the Staff’s request, each Trust hereby undertakes to revise the disclosure in the second paragraph under the heading “Segment Reporting” in the Notes to the Financial Statement as follows: “Each Fund operates as a single operating segment, which is a segregated investment portfolio. Royce , in its capacity serves as investment manager for each Fund. , The Management Committee of Royce functions as the Chief Operating Decision Maker ( “ CODM ” ) for each Fund for purposes of the Update, evaluating its results and performance based upon its specific investment strategy and other relevant facts and circumstances. The CODM uses these measures to assess Fund performance and allocate resources effectively, subject to compliance with applicable legal and regulatory requirements and oversight from its Board of Trustees. Internal reporting provided to the CODM aligns with the…

In response to the Staff’s request, each Trust hereby undertakes to revise the disclosure in the second paragraph under the heading “Segment Reporting” in the Notes to the Financial Statement as follows: “Each Fund operates as a single operating segment, which is a segregated investment portfolio. Royce , in its capacity serves as investment manager for each Fund. , The Management Committee of Royce functions as the Chief Operating Decision Maker ( “ CODM ” ) for each Fund for purposes of the Update, evaluating its results and performance based upon its specific investment strategy and other relevant facts and circumstances. The CODM uses these measures to assess Fund performance and allocate resources effectively, subject to compliance with applicable legal and regulatory requirements and oversight from its Board of Trustees. Internal reporting provided to the CODM aligns with the…

The Company acknowledges the Staff’s comment. The first sentence of ASC 280-10-50-26A states “A public entity shall disclose for each reportable segment the significant expense categories and amounts that are regularly provided to the chief operating decision maker and included in reported segment profit or loss.” With respect to the Real Estate Properties segment, the Company respectfully advises the Staff that the Company’s chief operating decision maker (“CODM”) uses the total property operating expenses (“Property Operating Expenses”) as presented on the Company’s consolidated statement of operations to review the performance of this segment. Further, the components of Property Operating Expenses, such as those mentioned in the sentence referenced in the Staff’s comment, are not regularly provided to the CODM and as such do not qualify as significant operating expenses under ASC…

We acknowledge the Staff’s comment. As noted in the Staff’s comment, during the second quarter of 2025, we started operating 13 of our properties through our REIT Investment and Diversification and Empowerment ACT (RIDEA) platform that was launched in May 2025. The RIDEA platform, or seniors housing operating portfolio (SHOP), allows us to earn income from the net operating income of our healthcare properties, rather than solely from traditional leasing arrangements. Previously, these 13 properties were leased to regional seniors housing operators under master leases. As a result of the launch of the SHOP platform which has a structure that is different than our other real estate investments, the way we manage and view our business changed. Therefore, we began reporting our operations through two reportable segments beginning in the second quarter of 2025. In preparing the segment…

Comment acknowledged and the requested information regarding ASC Topic 280 - Segment Reporting has been included in the amended Registration Statement under the heading “Item 2. Financial Information. – Management’s Discussion and Analysis of Financial Condition and Results of Operations - Segment Reporting”. 29. Staff

The Trust notes that ASU 2023-07 provides that a fund shall disclose “the title and position of the individual or the name of the group or committee identified” as the CODM. Accordingly, the Trust believes that the current disclosure, identifying the Adviser as CODM, conforms to the requirements of ASU 2023-07 and is consistent with standard industry practice. However, the Trust undertakes to consider disclosing additional information about the individuals fulfilling the CODM role for the Adviser in future financial statements filed with the SEC.

The Trust responds by confirming that the Adviser was incorrectly identified as the CODM. The CODM function is being carried out collectively by the chief executive officer, chief financial officer and chief operating officer of the Adviser. The CODM will be correctly identified in future reports filed with the Commission.. We believe that this submission fully responds to your comments If you have any questions regarding the above response, please do not hesitate to contact Rachel Spearo of U.S. Bank Global Fund Services, the Trust’s sub-administrator, at (414) 516-1692 or rachel.spearo@usbank.com . Sincerely, / s/ Thomas J. Fuccillo Thomas J. Fuccillo Chief Legal Officer cc: J.G. Lallande, Esq. Carl Gee, Esq. Rachael Schwartz, Esq.

The Company respectfully acknowledges the Staff’s comment and has added a new section titled “ Segment Information ” to address how the Company complies with the reportable segment disclosure requirements pursuant to ASU 2023-07 on page F-10 of Amendment No. 1. * * * U.S. Securities and Exchange Commission September 9, 2025 Page 5 The Company and its management acknowledge they are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comment, action or absence of action by the Staff. If you have any questions regarding the matters discussed above, please telephone the undersigned, outside counsel to the Company, at (415) 615-6095 or via email at Jeffrey.Selman@us.dlapiper.com. Sincerely, /s/ Jeffrey C. Selman Jeffrey C. Selman cc: Avi S. Katz Enclosures

The Registrant confirms that it will make the following adjustments in future financial reports: “The Fund’s President and Chief Financial Officer act as the chief operating decision maker (“CODM”), assessing performance and making decisions about resource allocation.” ***** We trust that the foregoing is responsive to your comments. Questions and comments concerning this filing may be directed to the undersigned at (212) 248-3298 or, in my absence, to Joshua Deringer at (215) 988-2959. Sincerely, /s/ Joshua Lindauer Joshua Lindauer 2

The Company acknowledges the Staff’s comment. Although certain segment disclosures required under ASC 280-10-50-20 through 50-31 and 280-10-55-15D through 55-15F were inadvertently omitted from the 2024 10-K and the Q1 2025 10-Q, in the Company’s Quarterly Report on Form 10-Q for the fiscal quarter ended June 30, 2025, filed with the Commission on August 14, 2025 (the “Q2 2025 10-Q”), the Company included the following segment disclosures (see Notes to Unaudited Consolidated Financial Statements—Segment Reporting , beginning on page F-54): Note 12 – Segment Reporting The Company operates in two reportable segments: Energy Infrastructure and Mobile Fuel Delivery. The Company’s segments were determined based on the economic characteristics of its products and services, its internal organizational structure, the manner in which operations are managed and the criteria used by the Company’s…

In future filings, the Registrant will include the President of the Funds as CODM, as part of the segment reporting disclosure in the Notes to Financial Statements in accordance with ASU 2023-07 – Segment Reporting (Topic 820). 3.

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 acknowledges the Staff’s comment regarding ASC 280-10-50-29(f) requirement to disclose: “How the chief operating decision maker uses the reported measure(s) of segment profit or loss in assessing segment performance and deciding how to allocate resources.” As discussed within our response to the Staff’s first comment above, the Company’s CODM uses adjusted operating income by segment as the only measure of segment profit or loss to evaluate segment performance and make resource allocation decisions. Management believes that adjusted operating income by segment provides a consistent view of the underlying operating performance of the business, excluding non-recurring transactions and activities that we do not consider to be indicative of our ongoing operating performance. The Company will revise its Business Segments Information footnote disclosure in future filings to…

The Company acknowledges the Staff’s comment and respectfully advises that as explained in the previous response letter, there were no retrospective adjustments to the consolidated financial statements related to the basis of presentation and segment reporting and therefore there was no need for the predecessor auditor to have included the carve out from their opinion. As a result, the Company is filing contemporaneously with the Commission Amendment No. 1 with the inclusion of an updated opinion from the predecessor auditor which does not include reference to the exclusion of the retrospective changes to its Annual Report on Form 20-F for the fiscal year ended December 31, 2024 (the “ Original Form 20-F ”), which was filed with the Commission on April 29, 2025 in response to the Staff’s comment. Except as expressly described above, Amendment No. 1 does not amend, supplement, or update…

We acknowledge the Staff’s comment and appreciate the guidance regarding our significant customer disclosures. We will revise our disclosures in future filings, beginning with our 2025 Form 10-K, to comply with FASB ASC 280-10-50-42 by: ● Identifying each customer whose revenues individually accounted for 10% or more of total revenues within each revenue classification (delivered energy, capacity, and third-party coal sales), ● Disclosing the specific amount of revenue attributable to each such customer, and ​ ● Specifying the segment in which the revenue is reported. 3 ​ ​ An example template of the proposed disclosure table is presented below: ​ ​ ​ Year Ended ​ ​ Segment December 31, 2025 December 31, 2024 ​ Customer A Electric Operations ​ ​ Customer B Electric Operations ​ ​ Customer C Coal Operations ​ ​ ​ We confirm that similar disclosures on pages 23 and 51 will also be updated…

We note the Staff’s comment and respectfully advise the Staff that we have revised Note 2 accordingly to provide the enhanced information required by ASU No. 2023-07, Segment Reporting (Topic 280): Improvements to Reportable Segment Disclosures. We hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact our securities counsel William S. Rosenstadt, Esq., or Jason Ye, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, or jye@orllp.legal. Vistek Limited /s/ Teck Hong Ho Name: Teck Hong Ho Title: Chief Executive Officer

The Trust acknowledges that not all personnel at the advisor are acting as CODM and as requested will correct this disclosure in future reports to reflect the Officers of ProFunds, collectively act as CODM. 4.

The Company acknowledges the Staff’s comment and has revised Note 3 to the audited consolidated financial statements as of and for the years ended December 31, 2024 and 2023 on page F-39 and Note 3 to the unaudited interim consolidated financial statements as of and for the six months ended June 30, 2025 and 2024 on page F-12 to include segment reporting disclosures required by ASU 2023-07 and ASC 280. We believe the foregoing is responsive to the Staff’s comments and requests for additional information. Please be advised that the Company wishes to have the registration statement declared effective as soon as possible. Accordingly, should you have any questions or need any additional information, please do not hesitate to contact the undersigned at (312) 609-7835 or Daniel C. McKay, II at (312) 609-7762. Very truly yours, /s/Jennifer Durham King Jennifer Durham King Shareholder,…

For Registrants with reporting periods ending 1/31/2025 and 2/28/2025, the disclosure included in each Registrant’s Form N-CSR relating to Segment Reporting and identification of the CODM was updated to replace the Management Committee of the fund’s adviser with the Chairman’s Committee of the fund’s adviser as a result of an internal corporate restructuring, which became effective at the fund’s adviser on 1/1/2025. In connection with this restructuring the Management Committee of the fund’s adviser was disbanded and replaced with a new internal committee oversight structure, which included, among other things, the creation of the Chairman’s Committee. We believe that the Chairman’s Committee satisfies the requirements of the CODM, as set forth in FASB’s Accounting Standards Codification (“ASC”) 280-10-50-1, namely by providing oversight of resource allocation and assessment of…

In response to the Staff’s comments, the Company has revised its disclosures on pages F-12 and F-13 of the Registration Statement. U.S. Securities and Exchange Commission Division of Corporate Finance August 13, 2025 Page 4 General

In response to the Staff’s comments, the Company has considered the guidance included in PCAOB Staff Questions and Answers on Adjustments to Prior-Period Financial Statements Audited by a Predecessor Auditor, PCAOB AS 3105.54 through .58 and PCAOB AS 3110.06 and confirms that there were no changes made by the company related to the Company’s basis of presentation and segment reporting footnote made related to the consolidated financial statements for each of the two years in the period ended December 31, 2023 that were included in the Company’s Form 20-F for the year ended December 31, 2024. Specifically, Note 2(a) pertains to the description of the Company's financial condition as of the end of fiscal year 2024 and the following 12 months in compliance with the disclosure requirements of ASC 205-40-50 and no retrospective adjustments were made to the comparable disclosure in the prior…

We note the Staff’s comment and, in response thereto, respectfully advise the Staff that we have revised page F-31 of the F-1/A-11 to include the disclosure as required. We hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact the Company’s securities counsel Mengyi “Jason” Ye, Esq. or Yarona L. Yieh, Esq. of Ortoli Rosenstadt LLP at jye@orllp.legal or yly@orllp.legal. Very truly yours, /s/ Darren Hoo Wei Sern Name: Darren Hoo Wei Sern Title: Executive Director, Chairman and Chief Executive Officer (Principal Executive Officer)

The Registrant confirms that the commitments listed in note 11 of the Notes to Consolidated Financial Statements were fair valued and it recorded unrealized gain/loss on the commitment. As noted in the response to Comment #1 above, the Registrant notes that the commitment is funded. The Registrant confirms that, going forward, it include these disclosures in the financial statements. Comment #11 In future financial statements, please disclose and discuss with more specificity the reasons for the transfers into and out of Level

In response to the Staff’s Comment, in future filings, we will remove the All Other column and will reconcile reportable segment operating income to consolidated income before income tax. 4. Please tell us how you have complied with the guidance in ASC 280-10-50-40 to provide revenue for each product and service or each group of similar products and services. In accordance with ASC 280-10-50-40, our disclosure for each group of similar products is our specialized end market platforms which includes Data Center, Gaming, Professional Visualization, Automotive, and OEM and Other within our fiscal year 2025 Form 10-K Note 16. The Revenue by End Market disclosure represents different types of primarily hardware sales for specialized markets. The Data Center revenue was further disaggregated between Compute and Networking based on similar products offered to Data Center customers. See further…

As noted by the Staff and presented within Part II, Item 7 Company’s Management’s Discussion and Analysis of Financial Condition and Results of Operation of the Company’s Form 10-K for the fiscal year ended February 28, 2025, the Chief Operating Decision Maker for BlackBerry assesses performance of the Company’s reportable operating segments through two metrics: segment gross margin, and segment adjusted EBITDA. In determining the disclosures required within the Notes to the Consolidated Financial Statements of Part I, Item 8 Financial Statements and Supplementary Data of the same Form 10-K, the Company considered ASC 280-10-50-28A, which states “ If the chief operating decision maker uses more than one measure of a segment’s profit or loss in assessing segment performance and deciding to allocate resources, a public entity may report one or more of those additional measures of segment…

The primary additional amounts included in "Other" are facility-related expenses and advertising costs. However, corporate allocations of shared costs is the largest component in “Other”. Beginning with our next Form 10-Q filing for the quarter ended June 30, 2025, we will revise footnote (a) to read: (a) Other expenses primarily include corporate allocations of shared costs, facility-related expenses, advertising costs, and Equity loss (income) in unconsolidated investees, net, which are not separately provided to the CODM. Corporate allocations of shared costs include, but are not limited to, technology, finance, analytics, legal, and human resources, as well as other general business costs. * * * * * 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…

In response to the Staff’s comment, we have revised the disclosure accordingly. Item 15. Recent Sales of Unregistered Securities, page II-3

In response to the Staff’s comment, the Company notes that it considered whether these metrics that are disclosed in its earnings presentations should also be presented in its periodic filings. In determining not to include these metrics in its periodic filings, the Company took into account that it does not view either book-to-bill or gross profit book-to-bill as key performance indicators for managing its business . Rather, the Company discloses these measures as additional supplemental color to illustrate to investors the quality of our signings growth. The book-to-bill and gross profit book-to-bill calculations are derived from signings over the trailing twelve months. These signings-dependent metrics illustrate the Company’s progress in executing on its strategic and growth initiatives and the Company’s value proposition over the long term. As previously discussed, the Company…

In response to the Staff’s comment, the Company respectfully proposes to revise the referenced disclosure as follows (page reference is made to the 2024 Form 20-F to illustrate the approximate location of the disclosure) in its future Form 20-F filings (with deletions shown as strike-through and additions underlined), subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed: Page F-32 The Group’s CODM has been identified as the Chief Executive Officer who reviews the consolidated results of operations when making decisions about allocating resources and assessing performance of the Group. The Group’s CODM manages the Company’s business activities as a single operating and reportable segment at the consolidated level. Accordingly, the Group’s CODM uses consolidated net income to measure segment profit or loss,…

In response to the Staff’s comment, the Company has amended the disclosure in Note 18 to more clearly specify the primary performance measure utilized by both management and the CODM in evaluating operating results and allocating resources. Thank you for the opportunity to respond to your comment on the Registration Statement. If you have additional questions or comments, please contact me at bj@offthehookys.com or 561-599-0080. Very truly yours, Brian John Chief Executive Officer Off The Hook YS Inc. 1701 Jel Wade Dr. Wilmington, NC 28401

In response to the Staff’s comment, the Company has revised the notes to the Financial Statements included in Amendment No. 1 to discuss how it complied with the referenced reportable segment disclosure requirements. Please see Note 8 to the Financial Statements included in Amendment No. 1. Should you have further comments or require further information, or if any questions should arise in connection with this submission, please call the undersigned at (346) 348-0239 or at (425) 802-9052. You also may contact the undersigned by email at kelvinkesse@kessepllc.com. Yours truly, /s/ Kelvin Kesse Kelvin Kesse cc: Bhargav Marepally, Chief Executive Officer of StoneBridge Acquisition II Corporation StoneBridge Acquisition II Corporation www.kessepllc.com

We acknowledge the Staff’s comment and respectfully advise the Staff that in future filings we will expand our disclosures to include segment cost of sales and segment operating expenses and we will explain the nature of the significant segment expenses within each category. Henry Schein, Inc., 135 Duryea Road, Melville, NY 11747 We acknowledge that Henry Schein, Inc. and its management are responsible for the accuracy and adequacy of its disclosures, notwithstanding any review, comments, action or absence of action by the SEC staff. If you have any questions or comments regarding this response, please contact me at ronald.south@henryschein.com. Sincerely, /s/ Ronald South Ronald South Senior Vice President and Chief Financial Officer 2

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…

Our “Corporate and Other” column does not include the results of any non-reportable operating segments. Rather, it consists solely of: – Corporate-level administrative expenses, such as executive management, finance, legal, HR, and other centralized functions not allocated to segments; and – Results related to the runoff of a legacy business, which is no longer a separate operating segment and is managed at the corporate level. To address the Staff’s comment, and in consideration of ASC 280-10-55-48, we will revise future disclosures in our Segment reporting footnote to our financial statements (generally Note 12 in our Form 10-Q filings) beginning with our next Form 10-Q filing for the quarter ending June 30, 2025 as follows: Reconciliation of Segment Adjusted EBITDA to Loss before income taxes Year ended December 31, 2024 Domestic Gannett Media $ 202,421 Newsquest 53,409 Digital…

As required by Item 303(b) of Regulation S-K, the Company describes in the MD&A the extent to which material changes in revenue from period-to-period are attributable to price, volume or amount of goods sold, or new products. In the 2024 Form 10-K, the Company provided an analysis of the material factors that impacted revenue on a consolidated and segment basis in order of magnitude and relative impact of each factor. On page 18, the Company stated that when discussing results, “unless otherwise noted, changes in our revenue are attributable to changes in customer demand, which are evidenced by fluctuations in shipment volumes.” In addition, on page 18, the Company noted that “from time to time, our revenue and gross profit are affected by changes in demand for higher-priced or lower-priced products, which we refer to as changes in the “mix” of products shipped” and that “new products…

The Company conveys the magnitude and relative impact of each material factor identified on both a consolidated and segment basis from period-to-period in accordance with Item 303(b) of Regulation S-K, in order to enhance a reader’s understanding of certain line items from the results of operations. For example, on page 19 in the Company’s 2024 Form 10-K, the Company noted that “gross profit of $9.09 billion was down $1.93 billion, or 17.5%, primarily due to lower revenue and, to a lesser extent, higher manufacturing costs associated with our planned capacity expansions.” The Company quantified on page 19 that “revenue of $15.64 billon decreased $1.88 billion or 10.7%, due to lower revenue from Analog and Embedded Processing.” On page 28, the Company quantified in the Consolidated Statements of Cash Flows the amount of $1.5 billion for depreciation costs, which is described in the MD&A…

Please be advised that we have amended the disclosures on page F-49 of the 10-K/A and page 28 of the 10-Q/A per the Staff’s comment as follows: The Company’s CODM is responsible for reviewing the results of operations and allocating resources across the Company’s reportable segments, including Fish Trading and Catering Services. These operating segments reflect the manner in which the CODM allocates resources and evaluates performance. These segments align with how management evaluates performance and allocates resources. Segment performance is evaluated based on segment revenue and operating profit, which includes direct costs and segment-specific general and administrative expenses and tax, but excludes corporate overhead and interest. 2 The summary of key information by segments for the years ended December 31, 2024 and 2023 was as follows: For year ended December 31, 2024 Sales of…

The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 80 and 82 of Amendment No. 1 to include quantification of the primary factors responsible for changes in Cost of Sales. With respect to quantifying the extent to which certain factors are responsible for changes in Segment Operating EBITDA however, the Company believes that the most prominent factor responsible for changes in Segment Operating EBITDA is volume, which is addressed throughout the section entitled “Management’s Discussion and Analysis of Financial Condition and Results of Operations”, and any items that have been described as offsetting the change in volume are not significant in the periods presented. Liquidity and Capital Resources, page 75

We acknowledge the Staff’s comment and respectfully submit the following: In accordance with ASC 280-10-50-26A, a public entity shall disclose for each reportable segment the significant expense categories and amounts that are regularly provided to the chief operating decision maker and included in reported segment profit or loss. While our CODM regularly reviews net sales and gross profit by reportable segment as key performance measures, cost of sales is not separately provided to or reviewed by the CODM on a segment basis. The CODM does not assess individual segment performance based on cost of sales, nor is cost of sales used in allocating resources or making operating decisions. Although gross profit is mathematically derived from net sales and cost of sales, segment-level cost of sales is not separately tracked or reported to the CODM, and therefore is not regularly reviewed or…