May 12, 2026

Ryan Carrithers
Chief Financial Officer
Merlin, Inc.
100 Causeway, Floor 23
Boston, MA 02114

        Re: Merlin, Inc.
            Registration Statement on Form S-1
            Filed May 6, 2026
            File No. 333-295578
Dear Ryan Carrithers:
       This is to advise you that we have not reviewed and will not review your
registration
statement.
       Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you that
the company and its management are responsible for the accuracy and adequacy of
their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.
       Please contact Uwem Bassey at 202-551-3433 or Jan Woo at 202-551-3453
with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:    Stephen W. Ranere