August 22, 2024

Bruce Lucas
Chief Executive Officer
Slide Insurance Holdings, Inc.
4221 W. Boy Scout Blvd.
Tampa, FL 33607

        Re: Slide Insurance Holdings, Inc.
            Draft Registration Statement on Form S-1
            Submitted August 5, 2024
            CIK No. 0001886428
Dear Bruce Lucas:

     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
July 16, 2024 letter.

Draft Registration Statement on Form S-1
Prospectus Summary, page 1

1.     We note your response to prior comment 3 and revised disclosure
following the statement
       that you believe you have a significant technological advantage. It is
unclear if you
       believe other companies' technologies do not allow them to estimate
future costs and
       compare back to base rates to "better understand profitability in real
time on an individual
       risk basis and to assess large and/or bulk transactions." It is also
unclear if you believe
       other companies' technologies do not permit them to only select policies
that they "believe
       to be profitable" based on metrics such as "future reinsurance and AOP
costs." Please
       provide a basis for the statement that you have "a significant
technological advantage."
 August 22, 2024
Page 2

Our Organizational Structure, page 9

2.     We note your response to prior comments 6, 9 and 11. We also note from
your
       disclosure concerning Slide Specialty Insurance Inc. that you do not
believe you will
       receive regulatory approval to be licensed in the State of South
Carolina prior to the
       effectiveness of the registration statement. However, your organization
chart, reflecting
       your structure immediately following the IPO, includes Slide Specialty
Insurance.
       Additionally, it appears from the revised definitional disclosure on
page 15 that Slide
       Specialty is no longer part of a "Carrier"; however, you continue to
state in the last
       paragraph on page 21 and imply elsewhere that your "Carrier is legally
permitted to write
       insurance" in South Carolina. Please revise to clarify the regulatory
nature of insurance
       underwriting prior to regulatory approval. Please also clarify, if
necessary, the extent to
       which "admitted" carrier status plays a part in the transition to
underwriting insurance
       prior to regulatory approval.
Risk Factors, page 15

3.     We note your response to comment 5. Please revise to include a new risk
factor or expand
       the third risk factor on page 31 to further clarify the risks associated
with being
       concentrated in two "coastal specialty zone" states. We note the
statement in
       your response to comment 5 that other insurers choose to minimize
exposure to the unique
       risks and environmental challenges of those areas. We also note that the
first full risk
       factor on page 50 mentions hurricanes and other east coast-related risks
but appears
       generally applicable to homeowner insurance businesses and a wide range
of risks from,
       for example, tsunamis, earthquakes, terrorism or war. Your revised risk
factor should
       address the specific risks, if material, in South Carolina and Florida
of regulatory and
       legislative bodies "restrict[ing] certain policy non-renewals or
cancellations and
       require[ing] advance notice of certain policy non-renewals ... or
limit[ing] or
       delay[ing] rate changes for a specified period during or after a
catastrophe event," as
       referenced on page 104.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
72

4.     We note your response to prior comment 19 and reissue. Please revise
your Management's
       Discussion and Analysis of Financial Condition and Results of Operations
to discuss your
       financial condition. Specifically, please discuss and analyze material
line items, and
       material changes period-over-period in those line items, on your
consolidated balance
       sheets, as well as the underlying reasons for those material changes in
quantitative and
       qualitative terms. Please refer to Item 303 of Regulation S-K.
Expenses, page 81

5.     We note your response to prior comment 22 and reissue. For instance we
note General
       and administrative expenses increased year-over-year from $39 million in
2022 to $88
       million in 2023 (a 125% increase). Please revise to quantify the primary
amounts driving
       the period over period changes within the General and administrative
expenses line
       item. Refer to Item 303 of Regulation S-K.
 August 22, 2024
Page 3
Business
Underwriting, page 94

6.     We note your disclosure on page 94 that each member of your Underwriting
Advisory
       Counsel has employment agreements. To the extent you have compensation
or other
       agreements with directors or officers on the underwriting team, please
confirm you have
       filed such agreements under Item 601(b)(10) of Regulation S-K.
Government Regulation, page 102

7.     We note your response to prior comment 29 and revised disclosure on page
104 with
       additional discussion of regulation in Florida. Please revise your
Government Regulation
       disclosure beginning on page 102, or where appropriate, to further
describe the economic
       and regulatory environment as they relate to South Carolina.
Notes to Consolidated Financial Statements
1. Nature of Business and Significant Accounting Policies, page F-9

8.     We note your response to prior comment 33. We also note your revised
disclosure on
       page 80 which clarifies that policies from Citizens were assumed,
whereas policies from
       St. Johns Insurance Company and UPC were acquired. Please also revise
your disclosure
       to summarize your initial recognition and measurement of acquired
policies. Please tell us
       the authoritative guidance upon which you relied.

       Please contact Katharine Garrett at 202-551-2332 or Lory Empie at
202-551-3714 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Aisha Adegbuyi at 202-551-8754 or James Lopez at 202-551-3536 with any
other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Finance
cc:   Richard D. Truesdell, Jr., Esq.