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                                                            September 18, 2024

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

       Re: Webull Corporation
           Amendment No. 4 to Draft Registration Statement on Form F-4
           Submitted August 28, 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
August 27, 2024 letter.

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

1.     Refer to your response to comment 1 in our letter dated July 25, 2024.
Please provide
       additional detail supporting your analysis of whether the offer and sale
of the fractional
       bonds through the fractional bond trading program represents the offer
and sale of a
       separate or new security. In your response, address the following:
           Tell us whether you have determined a potential launch date for the
program.
           Explain to us the consequences and risks to you and your customers
if Apex were to
           stop offering the program. In responding to this comment, explain
whether there are
           unique liquidity risks associated with fractional bonds, such as
whether investors will
           be reliant on the administrating firms such that if one were to go
out of business
 September 18, 2024
Page 2

           investors would not have other means to sell fractional bonds they
hold.
             Explain to us the consequences and risks to you if it were
determined that the
           fractional bonds offered though the program were themselves
securities, separate
           from the bonds themselves.
             Given the role of Apex in the operation of the program, explain
why its efforts are not
           the significant ones upon which investors are relying, and those
efforts continue
           throughout the lifecycle of a particular fractional bond purchase.
We note that: Apex
           designed, developed, implemented and operates the entire program;
Apex facilitates
           liquidity for the program by enlisting liquidity providers; Apex
selects the liquidity
           providers and there appears to be only one liquidity provider at
this time; Apex
           selects the bonds that are eligible for the program through
consultation with the
           liquidity providers; and Apex stands ready to assume or otherwise
allocate to another
           liquidity provider a liquidity provider   s positions in the event
the liquidity provider
           goes out of business or otherwise is no longer able to participate
in the program. As
           such, it appears that the entire program is dependent on the efforts
of Apex; that such
           efforts are not ministerial in nature; and that Apex has created an
instrument that
           otherwise would not exist and for which investors otherwise would
not be able to
           realize any investment outcome but for the efforts of Apex.
             Provide us a materially complete comparison of the legal rights
and recourse of a
           holder of a fractional bond versus a holder of a whole bond,
including the legal
           remedies that a holder of a fractional bond has versus a holder of a
whole bond,
           including under the Indenture.
             Provide additional detail of the mechanics and lifecycle of a
fractional bond trade,
           including coupon payments and other communications from the issuer.
             Explain how the principal and interest will be distributed to
fractional bond holders.
             Address whether fractional bond holders will have the same or
different rights as
           holders of whole bonds, including with respect to discretionary or
voluntary action
           and voting rights.
             Explain the implications of fractional bonds under the indenture,
including the impact
           of holding fractional bonds on the application of the Trust
Indenture Act of 1939.
             Provide us your analysis regarding FINRA Rule 5310 (Best Execution
and
           Interpositioning) for orders routed to Moment. Describe how Apex
will comply with
           FINRA Rule 5310(a)(2) and Supplementary Material .01, .03, .04, and
.06.
             Provide your analysis of whether interests in the program are
security-based swaps.
Webull Corporation Financial Statements
Note 2. Summary of Significant Accounting Policies
Marketing and Branding, page F-18

2.     We acknowledge your response to prior comment 3. Please respond to the
following
       comments related to your accounting for consideration payable to a
customer under ASC
       606-10-32-25 through 32-27 and, where appropriate, cite the
authoritative literature you
       rely upon to support your position:
           In identifying customers within the scope of this guidance, tell us
how you considered
           ASC 606-10-32-25 and Question 26 of the FASB's Revenue Recognition
 September 18, 2024
Page 3

           Implementation Q&As.
             In identifying consideration within the scope of the guidance,
tell us how you
           considered Question 25 of the FASB's Revenue Recognition
Implementation Q&As.
             You told us that the free stocks given to the platform users do
not result in your
           receipt of a distinct good or service from such platform users.
Regarding your referral
           program outlined on page 175 of your latest amendment, please
address the
           following:
             o For consideration paid to existing platform users:
                     Elaborate on why the referral of a new customer/user is
not a distinct
                     good/service as contemplated in ASC 606-10-32-25 as it
appears that users
                     are valuable to you.
                     If you believe you have received a distinct good or
service, tell us the nature
                     of that good or service and explain whether you can
estimate the fair value
                     of that good or service and whether the consideration paid
under the
                     program exceeds the fair value of that good or service,
consistent with the
                     guidance in ASC 606-10-32-26.
            o   For consideration paid to new users that become account
holders, tell us:
                    Whether they are required to subsequently contribute
additional
                    consideration to their account;
                    Whether they are required to execute trades on your
platform; or
                    Otherwise whether they are required to purchase any other
good or service
                    from you.
             Regarding the "Other Promotions" outlined at the bottom of page
175 of your latest
           amendment:
            o Tell us how these promotions work. Explain what users must do to
receive these
               awards.
            o For each period presented in your filing, tell us how much of
your marketing and
               branding expenses relate to these programs. In your response
tell us separately
               the amounts of cash and free stock paid under these programs.
            o Explain why consideration paid under these promotions is not a
reduction of
               revenue as either consideration payable to your customer or as
consideration
               paid to someone in the distribution channel of your customer.
             For consideration paid under the programs/promotions above, tell
us whether your
           market maker customers are aware of the consideration paid under
these programs
           and whether they have a reasonable expectation that you are granting
a price
           concession to your users.
 September 18, 2024
Page 4

       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
cc:   Christian O. Nagler
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