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Gear retracted AND 35 ft signal the end of the first segment.Off of the top of my head...
1st - From liftoff to gear retraction
Some airplanes (Hawkers, for example) use 1500 ft for this...I haven't looked it up, but I suspect it's a CAR4 vs Part 25 thing. The important thing is that you want to be above obstacles prior to leveling off for the third segment if you're IMC (or at least obstacles that you wouldn't clear by the time you fly miles and miles at a constant altitude during the...2nd - From gear retraction to 400' AGL
...or other appropriate altitude, as noted above.3rd - Acceleration to OEI climb speed at 400' AGL
or to basically the MEA if you're IMC.4th - 400' AGL at OEI climb speed to 1500' AGL