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                              January 20, 2023

       Timothy Sheehy
       Chief Executive Officer
       Wildfire New PubCo, Inc.
       90 Aviation Lane
       Belgrade, MT 59714

                                                        Re: Wildfire New PubCo,
Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted December
30, 2022
                                                            CIK No. 0001941536

       Dear Timothy Sheehy:

              We have reviewed your draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form S-1

       Cover Page

   1.                                                   For each of the
securities being registered for resale, please disclose the price that such
                                                        selling securityholders
paid for each of their securities or, to the extent applicable, the
                                                        price that such selling
securityholders paid for any securities overlying any securities
                                                        being registered for
resale. Please make conforming changes in the prospectus summary.
   2.                                                   We note your disclosure
that the each of the warrants "has an exercise price of $11.50 per
                                                        share of Common Stock,"
and that you "believe the likelihood that Warrant Holders will
                                                        exercise the Warrants .
.. . depends on the trading price of our Common Stock." Please
                                                        revise to also disclose
the market price of the underlying securities compared to the
                                                        exercise price of the
warrants, as you do on page 51, and if the warrants are out the
 Timothy Sheehy
Wildfire New PubCo, Inc.
January 20, 2023
Page 2
       money, please revise to disclose the likelihood that warrant holders
will not exercise their
       warrants. Provide similar disclosure in the prospectus summary, risk
factors, and
       Management   s Discussion and Analysis of Financial Condition and
Results of Operations
       section. As applicable, please also revise your Management   s
Discussion and Analysis of
       Financial Condition and Results of Operations section to describe the
impact on your
       liquidity and the ability of your company to fund your operations on a
prospective basis
       with your current cash on hand. If the company is likely to have to seek
additional capital,
       discuss the effect of this offering on the company   s ability to raise
additional capital.
Summary, page 7

3.     Please revise to highlight any differences in the current trading price,
the prices that the
       selling securityholders acquired their shares and warrants, and the
price that the public
       securityholders acquired their shares and warrants. Disclose that while
the selling
       securityholders may experience a positive rate of return based on the
current trading price,
       the public securityholders may not experience a similar rate of return
on the securities
       they purchased due to differences in the purchase prices and the current
trading price.
       Please also disclose the potential profit the selling securityholders
will earn based on the
       current trading price. Lastly, please include appropriate risk factor
disclosure.
Risk Factors
"Future sales, or the perception of future sales, of shares of our Common
Stock, by us or our
stockholders in the public market . . . ", page 46

4.     We note your disclosure that "[t]he sale of all or a substantial portion
of the Common
       Stock and Private Placement Warrants being offered for resale in this
prospectus or the
       perception that these sales could occur, could result in a significant
decline in the public
       trading price of our Common Stock and Warrants." To illustrate this
risk, please also
       disclose the initial purchase price of the securities being registered
for resale. To the
       extent that your current trading price is at or below Jack Creek
Investment Corp.'s initial
       public offering price, please also disclose that certain selling
securityholders may have an
       incentive to sell because they will still profit on sales of shares
purchased at lower prices
       as compared to the prices paid by public investors.
       Please contact Brian Fetterolf at 202-551-6613 or Donald Field at
202-551-3680 with
any questions.



                                                              Sincerely,
FirstName LastNameTimothy Sheehy
                                                              Division of
Corporation Finance
Comapany NameWildfire New PubCo, Inc.
                                                              Office of Trade &
Services
January 20, 2023 Page 2
cc:       Michael Heinz
FirstName LastName