SecProbe.io

CORRESP
1
filename1.htm

Newborn Acquisition Corp.

Room 801, Building C

Zhongshan East 2nd Road, Huangpu District

Shanghai, 200002, China

February 12, 2020

VIA EDGAR & TELECOPY

Ms. Susan Block

Division of Corporation Finance

Office of Transportation and Leisure

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549

 RE: Newborn Acquisition Corp. (the “Company”)

Registration Statement on Form S-1

(File No. 333-235788) (the “Registration Statement”)

Dear Ms. Martin:

The Company hereby
requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the Registration
Statement so that such Registration Statement will become effective as of 4:00 p.m. on February 13, 2020, or as soon thereafter
as practicable.

The Company hereby acknowledges that:

 · Should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority,
declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
Statement;

 · The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement
effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration
Statement; 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.

[Signature page follows]

Very truly yours,

NEWBORN ACQUISITION CORP.

By: /s/ Wenhui Xiong

       Name: Wenhui Xiong

       Title: Chairman and Chief Executive Officer