CORRESP 1 filename1.htm

May 23, 2025

Via Edgar

Division of Corporation Finance

Office of Energy & Transportation

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

Re: Wintergreen Acquisition Corp.

Registration Statement on Form S-1 (File No. 333- 286795)

Request for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned hereby join Wintergreen Acquisition Corp. in requesting that the Securities and Exchange Commission take appropriate action to cause the Registration Statement on Form S-1 (File No. 333-286795) (the “Registration Statement”) to become effective as of 4:00 p.m., Eastern Time, May 28, 2025, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Act, please be advised that we will take reasonable steps to secure adequate distribution of the prospectus to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement.

We have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, to the extent applicable.

	Very truly yours,
	D. Boral Capital LLC
	as representative of the underwriters
	By:	/s/ Philip Wiederlight
	Name:	Philip Wiederlight
	Title:	Chief Operating Officer