UPEXI, INC.

3030 ROCKY POINT DRIVE, SUITE 420

TAMPA, FL 33607

 

December 3, 2025

 

VIA EDGAR

 

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Crypto Assets

100 F Street, N.E.

Washington, DC 20549

 

 

Re:

Upexi, Inc.

 

 

Registration Statement on Form S-1, File No. 333-291879

 

REQUEST FOR ACCELERATION OF EFFECTIVENESS

 

Requested Date: December 5, 2025

Requested Time: 3:00 pm, Eastern Time

 

Ladies and Gentlemen:

 

Upexi, Inc. (the “Company”) hereby requests that the effective date of the Company’s Registration Statement on Form S-1, as amended (File No. 333-291879), be accelerated pursuant to Rule 461 under the Securities Act of 1933, as amended, so that it is declared and becomes effective at 3:00 pm Eastern Time on December 5, 2025, or as soon thereafter as possible.

 

Please contact our counsel Peter Campitiello of Lucosky Brookman LLP at (732) 395-4517 with any questions you may have regarding this request. In addition, the Company requests that you kindly notify Mr. Campitiello by telephone when this request for acceleration has been granted.

 

Sincerely yours,

 

 

 

UPEXI, INC.

 

 

 

/s/ Allan Marshall

 

Allan Marshall

 

Chief Executive Officer