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                                                              July 1, 2025

Alessandro Zamboni
Executive Chairman
Nuburu, Inc.
7442 S Tucson Way, Suite 130
Centennial, CO 80112

       Re: Nuburu, Inc.
           Registration Statement on Form S-1
           Filed June 16, 2025
           File No. 333-288095
Dear Alessandro Zamboni:

       We have conducted a limited review of your registration statement and
have the
following comment.

        Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-1 filed June 16, 2025
General

1.     We note that you seek to register up to (i) 6,086,957 shares of common
stock issuable
       to SFE EI, (ii) 2,830,189 shares of common stock issued to Coeptis and
(iii) 1,000,000
       shares of common stock issuable to Phoenix. In a PIPE transaction, a
registered resale
       of securities is permitted where the investor is irrevocably bound to
purchase a set
       number of securities for a set purchase price that is not based on a
market price or a
       fluctuating ratio. In addition, there can be no conditions to closing
that are within an
       investor   s control or that an investor can cause not to be satisfied.
Here, it appears that
       (i) the SFE EI and Phoenix shares may be future issuances where each
investor is not
       irrevocably bound to purchase a set number of securities for a set
purchase price and
       (ii) the Coeptis transaction contains a true-up adjustment. Please
provide us with your
       analysis regarding your eligibility to register the resale of the common
stock that may
 July 1, 2025
Page 2

       be issued pursuant to the above transactions. In your analysis, please
consider the
       guidance set forth in Securities Act Sections Compliance and Disclosure
       Interpretations Question 139.11.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Erin Donahue at 202-551-6063 or Evan Ewing at
202-551-5920 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing
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