May 11, 2026

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Robert Arzonetti

Re:      Neptune Insurance Holdings Inc.

Registration Statement on Form S-1

Submitted May 11, 2026

CIK No. 0002067129

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned registrant, Neptune Insurance Holdings Inc., a Delaware corporation (the “Registrant”), hereby requests that the above-referenced Registration Statement on Form S-1 (the “Registration Statement”) be declared effective at 4:00 p.m., Eastern Time, on May 13, 2026, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Orrick, Herrington & Sutcliffe LLP, by calling Mark Mushkin at (212) 506-3507.

The Registrant hereby authorizes Mark Mushkin of Orrick, Herrington & Sutcliffe LLP to orally modify or withdraw this request for acceleration.

Thank you for your assistance in this matter.

	Kind regards,
	NEPTUNE INSURANCE HOLDINGS INC.
By:	/s/ Jim Steiner
	Name:    Jim Steiner
	Title:    Chief Financial Officer

cc:       Trevor Burgess, Neptune Insurance Holdings Inc.

Jim Steiner, Neptune Insurance Holdings Inc.

Matt Duffy, Neptune Insurance Holdings Inc.

Michael J. Sullivan, Orrick, Herrington & Sutcliffe LLP

Mark Mushkin, Orrick, Herrington & Sutcliffe LLP