July 25, 2024

Anquan Wang
Chief Executive Officer
Webull Corporation
200 Carillon Parkway
St. Petersburg, FL 33716

       Re: Webull Corporation
           Amendment No. 2 to Draft Registration Statement on Form F-4
           Submitted June 17, 2024
           CIK No. 0001866364
Dear Anquan Wang:

     We have reviewed your amended draft registration statement and have the
following
comments.

        Please respond to this letter by providing the requested information
and either submitting
an amended draft registration statement or publicly filing your registration
statement on EDGAR.
If you do not believe a comment applies to your facts and circumstances or do
not believe an
amendment is appropriate, please tell us why in your response.

        After reviewing the information you provide in response to this letter
and your amended
draft registration statement or filed registration statement, we may have
additional
comments. Unless we note otherwise, any references to prior comments are to
comments in our
May 31, 2024 letter.

Amendment No. 2 to Draft Registration Statement on Form F-4
General

1.     We note from media reports and your website that users will be allowed
to trade fractional
       bonds on the Webull platform. Please tell us whether and to what extent
the fractional
       bond trading program is operational and describe to us the mechanics of
how this program
       works or will work, including the roles of Apex Fintech Solutions Inc.
and Moment
       Technology, Inc. Also provide your legal analysis under Section 2(a)(1)
of the Securities
       Act as to whether the offer and sale of fractional bonds or other fixed
income products
       through your platform represents a separate or new security. See
Abrahamson v.
       Fleschner, 586 F.2d 862 (2d Cir. 1977), and Gary Plastic Packaging Corp.
v. Merrill
       Lynch, Pierce, Fenner & Smith, Inc., 756 F.2d 230 (2d Cir. 1985).
 July 25, 2024
Page 2

Cover Page

2.     Refer to your response to comment 2. Please revise your disclosure here
and in the resale
       prospectus to state that the selling shareholders are underwriters.
Webull Corporation Financial Statements
Note 2. Summary of Significant Accounting Principles
Receivables from Customers, page F-9

3.     We acknowledge your response to the second bullet of prior comment 9. As
collectability
       being reasonably assured is not a criterion under the allowance guidance
in ASC 326,
       please revise your disclosure to remove that reference and instead refer
to the expected
       credit losses concept.
Marketing and Branding, page F-18

4.     We acknowledge your response to prior comment 12. You told us that your
platform users
       who receive free stocks in their brokerage accounts are not customers as
defined in ASC
       606 since they have not contracted with your broker-dealer subsidiary
for services in
       exchange for consideration, your platform users do not pay to access
your platform, and
       the market makers and liquidity providers who compensate your
broker-dealer subsidiary
       are customers within the scope of ASC 606. We note that in markets
outside of the
       United States, you typically charge commissions directly to your retail
customers. Please
       tell us whether these retail customers are customers within the scope of
ASC 606 and, if
       so, how you considered ASC 606-10-32-25.
Deferred Equity Offering Costs, page F-18

5.     We acknowledge your response to prior comment 13. We note that the
passage of time
       from your previous F-1 confidential submissions mentioned in your
response and your
       initial current F-4 confidential submission is significantly in excess
of the short
       postponement of up to 90 days as contemplated in SAB 5A. Please tell us
why this delay
       and the change to a de-SPAC transaction is not the abandonment of your
initially
       contemplated initial public offering necessitating the write-off of all
deferred costs
       directly related to that attempted offering.
Note 5. Discontinued Operations, page F-25

6.     We continue to evaluate your response to prior comment 14 and may have
additional
       comments.
 July 25, 2024
Page 3

       Please contact Kate Tillan at 202-551-3604 or Mark Brunhofer at
202-551-3638 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Sonia Bednarowski at 202-551-3666 or J. Nolan McWilliams at
202-551-3217 with any
other questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Crypto Assets