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                              September 22, 2023

       Robert McBey
       Chief Executive Officer
       Calculator New Pubco, Inc.
       4221 W. Boy Scout Blvd.
       Suite 300
       Tampa, FL 33607

                                                        Re: Calculator New
Pubco, Inc.
                                                            Amendment No. 4 to
Registration Statement on Form S-4
                                                            Filed September 6,
2023
                                                            File No. 333-271665

       Dear Robert McBey:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
August 11, 2023 letter.

       Amended Form S-4 filed September 6, 2023

       Risk Factors
       Wilson-Davis will need to obtain additional capital to meet increased
excess capital
       requirements, page 51

   1.                                                   We note your disclosure
that Wilson-Davis will need to obtain additional capital to meet
                                                        increased capital
requirements in order to continue to clear for an introducing broker.
                                                        Please expand to
explain how not meeting this additional capital requirement may impact
                                                        Wilson-Davis's business
so that investors can assess the risk. For instance, please explain
                                                        how much revenue the
company received last year from this aspect of the business, and
                                                        what percentage of
revenue that was.
 Robert McBey
Calculator New Pubco, Inc.
September 22, 2023
Page 2
Updated Projections, page 112

2.    We note your response to comment 1 and reissue in part. You state the
Updated
      Projections reflect "...reduced projections for increase in customers and
brokers in the first
      two years..." even though the Year 2 Updated Projections for total
revenue are higher than
      those for the Initial Projections. Please revise your disclosure to
clarify.
Wilson-Davis & Co., Inc Audited Financial Statements, page F-49

3.    Please revise to include the Report of Independent Registered Public
Accounting Firm for
      the audited financial statements presented for Wilson-Davis & Co.
       You may contact Lory Empie at (202) 551-3714 or Marc Thomas at (202)
551-3452 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Robert Arzonetti at (202) 551-8819 or Susan Block at (202) 551-3210
with any other
questions.



                                                             Sincerely,
FirstName LastNameRobert McBey
                                                             Division of
Corporation Finance
Comapany NameCalculator New Pubco, Inc.
                                                             Office of Finance
September 22, 2023 Page 2
cc:       Jason Simon
FirstName LastName