August 13, 2025
Dinakar Munagala
Chief Executive Officer
Blaize Holdings, Inc.
4659 Golden Foothill Parkway, Suite 206
El Dorado Hills, CA 95762
Re: Blaize Holdings, Inc.
Schedule 13D filed July 11, 2025 by Dinakar Munagala
File No. 005-93191
Dear Dinakar Munagala:
We have conducted a limited review of the above-captioned filing and
have the
following comment.
Please respond to this letter by amending the filing or by providing
the requested
information. If you do not believe our comment applies to your facts and
circumstances or
that an amendment is appropriate, please advise us why in a response letter.
After reviewing any amendment to the filing and any information provided
in
response to this comment, we may have additional comments.
Schedule 13D filed July 11, 2025
General
1. We note that the date of event reported as requiring the filing of the
Schedule 13D
was May 2, 2025. Rule 13d-1(a) of Regulation 13D-G requires the filing
of a
Schedule 13D within five business days after the date beneficial
ownership of more
than five percent of a class of equity securities specified in Rule
13d-1(i)(1) was
acquired. Based on the May 2, 2025 event date, the Schedule 13D
submitted on July
11, 2025 was not timely filed. Please advise us why the Schedule 13D was
not filed
within the required five business days after the date of the
acquisition.
August 13, 2025
Page 2
We remind you that the filing person is responsible for the accuracy
and adequacy of
his disclosures, notwithstanding any review, comments, action or absence of
action by the
staff.
Please direct any questions to Blake Grady at 202-551-8573 or Nicholas
Panos at
202-551-3266.
Sincerely,
Division of
Corporation Finance
Office of Mergers &
Acquisitions