December 18, 2024

Justin Cohen
Chief Executive Officer
Ategrity Specialty Holdings LLC
9 West 57th Street, 33rd Floor
New York, NY 10019

       Re: Ategrity Specialty Holdings LLC
           Draft Registration Statement on Form S-1
           Submitted on November 20, 2024
           CIK No. 0002040491
Dear Justin Cohen:

       We have reviewed your 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.

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

1.     Consistent with your disclosure on page 32, please disclose in the
prospectus
       summary that you commenced operations in 2018 and thus have a limited
operating
       history.
2.     Please provide support for the following statements or revise to make it
clear these are
       management's beliefs:
           the E&S industry was an under-served and inefficient marketplace
that was
           hindered by inconsistent and antiquated processes of legacy
insurance carriers;
           many distribution partners and their end-clients were struggling
with slow
           response times, unpredictable underwriting capacity and subpar
pricing; and
 December 18, 2024
Page 2

             many of your E&S competitors do not have highly diverse
distribution
           relationships.
3.     We note that on page 5 you first draw the comparison between the E&S
market in
       which you operate and admitted lines market. While we recognize that the
glossary
       defines these terms, please clarify in the prospectus summary that the
E&S market
       involves lines of insurance which are generally unavailable from
admitted insurers
       due to perceived risk related to the insured   s business and which,
consequently, are
       placed by surplus lines agents or brokers with insurers that are not
admitted in the
       subject jurisdiction. Also, briefly expand upon the distinctions between
these markets
       in the prospectus summary, and particularly that the non-admitted market
       comprises companies not licensed to transact the business of insurance
but
       are permitted to issue insurance policies only in accordance with an
exemption from
       insurance licensing laws, for example, through a licensed E&S lines
broker.
4.     Please disclose in your prospectus summary that a substantial portion of
your portfolio
       assets is allocated to the Utility & Infrastructure Investments, which
is comprised of
       investments in private investment funds managed by an affiliated entity.
Also include
       disclose here, consistent with your disclosure later in the document,
that the Utility
       & Infrastructure Investments are speculative, entail substantial risks
and are subject to
       various conflicts of interest, and that they are made through various
commingled
       investment vehicles that are managed on behalf of multiple clients of
the Investment
       Manager, and not structured in relation to your specific financial
objectives or
       anticipated insurance and reinsurance liabilities.
Controlled Company, page 10

5.     Please discuss here the controlling shareholders' ability to control
matters requiring
       shareholder approval, including the election of directors, amendment of
organizational
       documents, and approval of major corporate transactions, such as a
change in control,
       merger, consolidation, or sale of assets. Further, clarify here whether
you plan to rely
       on the    controlled company    exemptions from certain corporate
governance
       requirements. Alternatively, provide a cross-reference to the risk
factor disclosures
       beginning on page 47.
Risk factors
Severe weather conditions, page 14

6.     Please address in the risk factor if any geographic areas you serve are
exposed to any
       particular type of weather, earthquakes or other catastrophes.
Risk factors, page 18

7.     We note your disclosure on page 18 referencing A.M. Best   s financial
strength rating
       of Ategrity Specialty Holdings LLC   s Insurance and Bermuda
subsidiaries. Please
       revise the language throughout the document, as appropriate to clarify
that A.M.
       Best   s financial strength rating as quoted relates to the Company   s
Insurance
       Subsidiary (Ategrity Specialty Insurance Company) and the Bermuda
Subsidiary
       (Ategrity Specialty Insurance Limited).
 December 18, 2024
Page 3

Adverse economic factors, including recession, inflation, periods of high
unemployment or
lower economic activity, page 23

8.     We note that you underwrite a significant portion of your insurance in
California,
       Florida, Georgia, New York and Texas. Please disclose the relative
percentage of
       business in each respective state and also expand your disclosure in the
prospectus
       summary, MD&A and business section to discuss any material
concentrations.
Management's discussion and analysis of financial condition and results of
operations, page
59

9.     Please revise to provide a detailed discussion of the changes in
financial position for
       each of the periods presented.
Loss and loss adjustment expenses, page 64

10.    Please revise to include a discussion which addresses and quantifies the
changes in the
       individual components relating to the overall changes in the incurred
losses and loss
       adjustment expenses for the periods presented.
Our Business, page 80

11.    We note your disclosure that you stratify risk characteristics by
micro-segments, and
       you give examples in the hotel and motel industry of micro-segments.
Please further
       expand to explain other micro-segments that you analyze, or advise.
Principal stockholders, page 125

12.    Please identify the individual or individuals that have voting and
dispositive control
       over the shares owned by ZFSG. Refer to Item 403 of Regulation S-K.
Exclusive forum, page 129

13.    We note that your disclosure here provides that the forum selection
provision
       identifies the Court of Chancery of the State of Delaware as the
exclusive forum for
       certain litigation, including any    derivative action.    Please
disclose here whether this
       provision applies to actions arising under the Securities Act or
Exchange Act. If so,
       please also state that there is uncertainty as to whether a court would
enforce such
       provision. If the provision applies to Securities Act claims, please
also state that
       investors cannot waive compliance with the federal securities laws and
the rules and
       regulations thereunder. In that regard, we note that Section 22 of the
Securities Act
       creates concurrent jurisdiction for federal and state courts over all
suits brought to
       enforce any duty or liability created by the Securities Act or the rules
and
       regulations thereunder. If this provision does not apply to actions
arising under the
       Securities Act or Exchange Act, please also ensure that the exclusive
forum provision
       in the governing documents states this clearly, or tell us how you will
inform investors
       in future filings that the provision does not apply to any actions
arising under the
       Securities Act or Exchange Act. Please also reconcile your disclosure
about the
       exclusive forum provision here with the disclosure in your risk factor
on page 44 and
       update the risk factor to discuss that the provision may increase costs
to bring a claim.
 December 18, 2024
Page 4

Exhibit Index, page II-4

14.    We note the disclosure on page 110 that you intend to enter into an
employment
       agreement with Mr. Cohen prior to the completion of this offering.
Please confirm
       that you will file the employment agreement as an exhibit once you enter
into it and
       consider providing a placeholder in the exhibit index to the extent you
expect that it
       will be filed prior to effectiveness.
15.    Please file as exhibits the Utility Limited Partnership Agreement
referenced on page
       119 and the Master Technology Transfer Agreement referenced on page 122
or
       provide your analysis as to why you believe they are not required.
Please also
       confirm you will file the MidCap Limited Partnership Agreement
referenced on page
       120 once executed or provide your analysis as to why you believe it will
not be
       required. Refer to Item 601(b)(10) of Regulation S-K.
General

16.    Please provide us with copies of all written communications, as defined
in Rule 405
       under the Securities Act, that you, or anyone authorized to do so on
your behalf have
       presented or expect to present to potential investors in reliance on
Section 5(d) of the
       Securities Act, whether or not you retained, or intend to retain, copies
of those
       communications. Please contact the staff at the phone number below to
discuss how to
       submit the materials.
17.    Please provide us with copies of any additional graphics, maps,
photographs, and
       related captions or other artwork including logos that you intend to use
in the
       prospectus. Please keep in mind, in scheduling printing and distributing
of the
       preliminary prospectus, that we may have comments after reviewing the
materials.
       Please contact Victor Cecco at 202-551-2064 or Marc Thomas at
202-551-3452 if you
have questions regarding comments on the financial statements and related
matters. Please
contact John Stickel at 202-551-3324 or Susan Block at 202-551-3210 with any
other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Finance