WATON FINANCIAL LIMITED

VIA EDGAR

December 29, 2025

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: John Dana Brown

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), Waton Financial Limited (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1, as amended (the “Form F-1 Registration Statement”), be accelerated to, and that the Form F-1 Registration Statement become effective at, 4:00 p.m., Eastern Time on December 31, 2025, or as soon thereafter as practicable.

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