United States securities and exchange commission logo February 6, 2024 Bihua Chen Chief Executive Officer Helix Acquisition Corp. II 200 Clarendon Street, 52nd Floor Boston, MA 02116 Re: Helix Acquisition Corp. II Amendment No. 1 to Registration Statement on Form S-1 Filed February 2, 2024 File No. 333-276591 Dear Bihua Chen: We have reviewed your amended 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. Amendment No. 1 to Registration Statement on Form S-1 filed February 2, 2024 Risk Factors, page 32 1. We note your investment company risk factors beginning on page 41. Please disclose that if you are found to be operating as an unregistered investment company, you may be required to change your operations, wind down your operations, or register as an investment company under the Investment Company Act. Also include disclosure with respect to the consequences to investors if you are required to wind down your operations as a result of this status, such as the losses of the investment opportunity in a target company, and any price appreciation in the combined company. Please confirm that if your facts and circumstances change over time, you will update your disclosure to reflect how those changes impact the risk that you may be considered to be operating as an unregistered investment company. Bihua Chen FirstName LastNameBihua Helix Acquisition Corp. II Chen Comapany6,NameHelix February 2024 Acquisition Corp. II February Page 2 6, 2024 Page 2 FirstName LastName Please contact Paul Cline at 202-551-3851 or Isaac Esquivel at 202-551-3395 if you have questions regarding the financial statements and related matters. Please contact Ronald (Ron) E. Alper at 202-551-3329 or Pam Howell at 202-551-3357 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Joel Rubinstein