December 30, 2025

 

VIA EDGAR

 

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

Attention: Matthew Derby

 

  Re: Capstone Green Energy Holdings, Inc.
    Registration Statement on Form S-1
    Filed December 23, 2025
    File No. 333-292401

Ladies and Gentlemen:

 

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Capstone Green Energy Holdings, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it may become effective at 4:00 p.m. Eastern Time on January 2, 2026, or as soon as practicable thereafter.

 

Once the Registration Statement has been declared effective, please contact our counsel, Elizabeth McNichol of Katten Muchin Rosenman LLP, at (214) 765-3661 to orally confirm that event or if you have any questions or require additional information regarding this matter.

 

 

Sincerely, 

 

  /s/ Alfredo Gomez
  Name:   Alfredo Gomez
  Title:  General Counsel
   
cc: Vincent J. Canino, Chief Executive Officer
  Mark D Wood, Katten Muchin Rosenman LLP
  Elizabeth C. McNichol, Katten Muchin Rosenman LLP