SecProbe.io

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January 6, 2005

MAIL STOP 0511

Mr. Barry J. Gordon
Chairman of the Board and Chief Executive Officer
Ardent Acquisition Corporation
1415 Kellum Place, Suite 205
Garden City, New York 11530

      Re:	Ardent Acquisition Corporation
		Registration Statement on Form S-1
		Filed December 6, 2004
      File No. 333-121028

Dear Mr. Gordon:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. We note your reference to the term "Special Purpose Acquisition
Company" or "SPAC" throughout this registration statement.  We
further note that the acronym SPAC was used in previous
registration
statements but was defined as "Specific Purpose Acquisition
Company."
The staff at this time believes that there could be confusion in
the
use of the acronym SPAC in the current offering from earlier
references to the acronym which had a different meaning.  Further
the
staff is concerned that the use of the term special purpose
acquisition company may be confusing to investors because the
purpose
of the company appears to be the same as most other blank check
companies.

In order for the staff to further evaluate the use of the acronym
SPAC in the current offering, and with a view to disclosure in
your
prospectus, please provide the following: 1) the creator of the
term
"Special Purpose Acquisition Company;" 2) the arrangements under
which Ardent is allowed to use the term; 3) historical chronology
of
the use of the acronym SPAC; 4) the last time it was used and its
meaning at that time; 5) the previous definition of a specific
purpose acquisition company; 6) the definition of a special
purpose
acquisition company; and 7) how the company has a "special
purpose"
that is distinct from the ordinary definition of a blank check
company.

2. Prior to the effectiveness of the company`s registration
statement, the staff requests that we be provided with a copy of
the
letter or call from the NASD that the NASD has no additional
concerns.

3. Prior to effectiveness please provide an update with respect to
those states in which the offering will be conducted.

Prospectus Summary

4. We note the representation that the Special Purpose Acquisition
Company "will be able to acquire an operating business in any
industry which we believe has significant growth potential."  This
disclosure appears to be promotional and vague.  Although you
discuss
the technology industry later in the prospectus, we note that you
are
not limited to a specific industry.  If you will consider
industries
other than technology, please discuss the factors you will
consider
in assessing the growth potential of those industries later in the
prospectus.

Risk Factors
Risks related to the technology industry

5. Please revise your risk factor subheadings to state the
material
risk to potential investors.  In this regard, your subheadings
should
disclose the consequences to the investor or to the company,
should
the risk materialize.  For example, some of your subheadings
merely
state facts or describe uncertainties and do not adequately
reflect
the risks that follow.  Please see risk factors one and two under
this subsection.  Please revise the subheadings to succinctly
state
the risks.

Use of Proceeds

6. The company states in the first paragraph of the Use of
Proceeds
section that "[a]ny amounts not paid as consideration to the
sellers
of the target business may be used to finance operations of the
target business or to effect other acquisitions."  Please
reconcile
this statement with disclosure in the Use of Proceeds section and
in
the MD&A section that states "[t]o the extent that our capital
stock
is used in whole or in part as consideration to effect a business
combination, the proceeds held in the trust fund as well as any
other
net proceeds not expended will be used to finance the operations
of
the target business."
It would appear that to the extent that the company uses
stock/cash
or a combination of the two, any net proceeds would be used to
finance the operations of the target business.  Please revise the
registration statement accordingly.

Proposed Business
Introduction

7. We note the assertions under the subheading "Continued
worldwide
spending."  Please provide us supplementally with the reasonable
support for the assertions and summarize the support in your
prospectus.  If you cannot provide us with support for these
assertions, you should delete them.

8. We note that parts of the business section appear promotional,
rather than factual, and should be revised to remove all
promotional
statements.  No speculative information should be included, unless
clearly labeled as the opinion of management of the company along
with disclosure of the reasonable basis for such opinions or
beliefs.
For example we note the statement "we believe wireless
communications, the digital home and nanotechnology will continue
to
evolve into larger markets."  Please provide reasonable support
for
the promotional statement in the prospectus.  If a reasonable
basis
cannot be provided, the statement should be removed.

9. Please revise the business section to comply with the
requirements
of Rule 421 of Regulation C.  Please use definite concrete
everyday
words.  In the business section, you employ technical terms and
jargon that may be confusing and difficult for an average reader
to
understand.  For example, you include terms such as "IPO" and
"nanotechnology."  Please remove unnecessary technical terms or
jargon from the body of the prospectus. Where technical terms or
jargon have to be used, please explain them in ordinary, everyday
language when first used.

Management/Principal Stockholders

10. Please disclose whether management or current shareholders
have
any prior experience with blank check companies.

Financial Statements
General

11. Your attention is directed to Section 210.3-12 of Regulation
S-X
and the possible need for updated financial statements and related
disclosures.

12. You are reminded that a currently dated consent of the
independent accountants with typed signature should be included in
any amendment to the registration statement.

Closing Statements

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Maureen Bauer at (202) 942-1824 or Terence
O`Brien at (202) 942-1855 if you have questions regarding comments
on
the financial statements and related matters.  Please contact
Thomas
Kluck at (202) 824-5262, or me at (202) 942-2999 with any other
questions.

Sincerely,

      John Reynolds, Assistant Director
      Office of Emerging Growth Companies

cc:	David Alan Miller, Esq.
	Fax: (212) 818-8881
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Ardent Acquisition Corporation
January 6, 2005
Page 1 of 5

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