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CORRESP
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CORRESP

 December 7, 2022

VIA EDGAR

 Division of Corporation Finance

Office of Finance

 Securities and Exchange Commission

100 F Street, N.E.

 Washington, DC 20549-6010

Attention:

 John Spitz

 Michael Volley

Robert Arzonetti

 J. Nolan Williams

Re:

 East Resources Acquisition Company

Preliminary Proxy Statement on Schedule 14A

 Filed
October 14, 2022

 File No. 001-39403

FOIA Confidential Treatment Request

Under 17 C.F.R §200.83

 Ladies and Gentlemen:

On behalf of East Resources Acquisition Company (the “Company”), set forth below are the Company’s responses to
the comments of the Staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) relating to the Company’s Preliminary Proxy Statement on
Schedule 14A (the “Proxy Statement”). An electronic version of the Amendment No. 1 to the Preliminary Proxy Statement on Schedule 14A (the “Amended Proxy Statement”) has been concurrently filed
with the Commission through its EDGAR system.

 The Company respectfully requests confidential treatment for certain portions of this
letter pursuant to Rule 83 of the Commissions’ Rules on Information and Requests, 17 C.F.R. § 200.83. This letter is accompanied by such request for confidential treatment because of the commercially sensitive nature of the information
discussed in this letter. The copy filed herewith omits the information subject to the confidentiality request. Omissions are designated as [***]. A complete version has been separately filed with the Commission.

Set forth below are the responses of the Company to the comments of the Staff on the letter to the Company, dated November 10, 2022,
relating to the Proxy Statement. For convenience of reference, the text of the comments in the Staff’s letter has been reproduced in bold and italics herein. The Company has also provided its response immediately after each numbered comment.
Capitalized terms used but not otherwise defined herein have the meanings assigned to such terms in the Amended Proxy Statement.

 Basis of
Presentation and Glossary, page iv

1.
 Please tell us and revise to disclose if there is a PIPE Investment that will occur with the business
combination as we note references to a PIPE Investment Amount in the “aggregate transaction proceeds” definition as well as other references throughout the filing and also in Exhibit A to your Agreement and Plan of Merger in Annex
A.

 Response: As disclosed previously, the Company continues to opportunistically seek to raise a PIPE Investment
but at this time has no committed PIPE Investment amounts. Should the Company obtain PIPE Investments, the Company will revise its proxy statement to disclose the terms thereof.

2.
 Please revise to include “units” and “ERES units” in the glossary.

 Response: The Company has revised the Amended Proxy Statement in response to the Staff’s comment. Please see page vi
of the Amended Proxy Statement.

 December 7, 2022

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 What Equity Stake Will Current ERES Stockholders, the Initial Stockholder, and the Company Members Hold
in ERES following the Closing?, page viii

3.
 Please revise your disclosure to show the potential impact of redemptions on the per share value of the
shares owned by non-redeeming shareholders by including a sensitivity analysis showing a range of redemption scenarios, including minimum, maximum and interim redemption levels. Please also make conforming
changes on page 2 to the section entitled “Ownership of the Post-Combination Company.”

 Response: The Company
has revised the Amended Proxy Statement in response to the Staff’s comment. Please see pages ix-xii and 3-6 of the Amended Proxy Statement.

4.
 Please quantify the value of warrants, based on recent trading prices, that may be retained by redeeming
stockholders assuming maximum redemptions and identify any material resulting risks.

 Response: The Company has
revised the Amended Proxy Statement in response to the Staff’s comment. Please see pages xii and 54-55 of the Amended Proxy Statement.

Questions and Answers

 What Happens to the
Funds Deposited in the Trust Account After Consummation of the Business Combination?, page xiv

5.
 You disclose that $345,000,000 was raised in the IPO but that only $97,939,800.60 remained in the trust
fund because “in connection with the stockholder approval of such extension in July 2022, certain stockholders elected to redeem an aggregate of 24,781,028 Public Shares, or approximately 71.83% of the then outstanding Public Shares.”
Please revise the disclosure to include additional information regarding the redemption of 71.83% of the outstanding public shares.

Response: The Company has revised the Amended Proxy Statement in response to the Staff’s comment. Please see pages xvii-xviii of the
Amended Proxy Statement.

 Summary, page 1

6.
 Please revise to provide organizational charts for both the
pre-business and post-business combinations, including all entities and corresponding ownership percentages.

Response: The Company has revised the Amended Proxy Statement in response to the Staff’s comment. Please see pages 1-2 of the Amended Proxy
Statement.

 Risk Factors

 Life
settlements in which we invest are not currently regulated under the federal securities laws, page 31

7.
 You state that you intend that all purchases and sales of life insurance policies by you will comply with
all applicable federal and state securities laws. Please briefly describe the process undertaken to ensure such compliance.

Response: Transactions in non-fractional, non-variable, life insurance
policies, acquired either from the underlying insured or from a seller in a secondary or tertiary sale, are not securities under the federal securities laws. The Company’s principal business involves originating and trading insurance policies
that are not securities. The Company works closely with its outside regulatory counsel, Locke Lord LLP, to stay informed on developments in the life settlement industry, in particular with respect to the treatment of life settlement policies (i.e.
life insurance policies which have been sold by the original underlying insured) as securities. Abacus has developed internal guidelines to avoid purchasing life insurance policies which would be deemed to be securities.

 December 7, 2022

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 The Company has invested in 11 variable or fractionalized life insurance policies, i.e.
securities. When doing so, the Company conducts the transactions only through a duly registered broker-dealer. The Company has recently acquired a limited purpose broker-dealer. Abacus is in the process of incorporating this limited purpose
broker-dealer into the Company’s life insurance policies acquisition and disposition process. Until this broker-dealer has been fully integrated, including through the establishment of appropriate compliance policies and procedures around the
securities brokerage activity, the Company will rely on appropriate external resources to ensure that all variable and fractionalized life insurance policies are appropriately acquired.

There have been lawsuits in various states questioning whether a purchaser of a life insurance policy, page 34

8.
 Please revise to disclose the carrying value of STOLI policies held at each period end presented.

 Response: Abacus does not believe it has any STOLI policies. Abacus has policies in place to identify potential STOLI policies,
and will not invest in such policies, however there can be no guarantee that Abacus will identify all STOLI policies. Because of the disclosure requirements related to life insurance policies it may be impossible to determine if a particular life
insurance policy is a STOLI until a carrier seeks to rescind a policy on that basis or a carrier identifies an insured has had other STOLI policies bound on their life. Please see pages 39-40 of the Amended Proxy Statement.

We Have Identified Material Weaknesses In Our Internal Control Over Financial Reporting, page 38

9.
 Please revise to clarify which company identified the material weakness and more comprehensively describe
your current plans or actions already undertaken for remediating each identified material weakness.

 Response: The
Company has revised the Amended Proxy Statement in response to the Staff’s comment. Please see page 43 of the Amended Proxy Statement.

 ERES
stockholders will have a reduced ownership and voting interest after the Business Combination, page 43

10.
 Please disclose all possible sources and extent of dilution that shareholders who elect not to redeem
their shares may experience in connection with the business combination. Provide disclosure of the impact of each significant source of dilution, including the amount of equity held by founders, the note extension agreement, the Forward Purchase
Agreement, convertible securities, including warrants retained by redeeming shareholders, at each of the redemption levels detailed in your sensitivity analysis, including any needed assumptions.

Response: The Company has revised the Amended Proxy Statement in response to the Staff’s comment. Please see pages ix-xii, 3-6 and 48 of the
Amended Proxy Statement. Please note that we did not include in these revisions any shares that were issuable under the Forward Purchase Agreement as the Company and East Resources Management, LLC entered into an agreement to terminate the Forward
Purchase Agreement on December 2, 2022, pursuant to which the Forward Purchase Agreement is of no further force and effect.

 December 7, 2022

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 ERES directors and officers may have interests in the Business Combination different from the interests
of ERES stockholders, page 45

11.
 Please quantify the aggregate dollar amount and describe the nature of what the sponsor and its
affiliates have at risk that depends on completion of a business combination. Include the current value of securities held, loans extended, fees due, and out-of-pocket
expenses for which the sponsor and its affiliates are awaiting reimbursement. Provide similar disclosure for the company’s officers and directors, if material. Please also disclose the current balance of the Extension Note.

 Response: The Company has revised the Amended Proxy Statement in response to the Staff’s comment. Please see pages xx-xxiv, 7-11, 51-54, 83-87, and 201-205 of the Amended Proxy Statement.

Accounting for the Business Combination, page 59

12.
 We note your disclosure that LMA was determined to be the accounting acquirer. Please tell us the
specific key facts and circumstances related to ERES, LMA and Abacus and how you applied the guidance in ASC 805-10-55-10 through
55-13 in making your determination.

 Response: We first considered ASC
805-10-55-10 and determined that neither Abacus nor LMA represent a variable interest entity as they do not meet any of the three criteria under ASC 810-10-15-14. Accordingly, there is no clear accounting acquirer based on one of the entities being
a VIE.

 Accordingly, we next considered ASC 805-10-55-11 but deemed the paragraph not to be applicable as the business combination is effected primarily
by exchanging equity interests.

 We then considered ASC 805-10-55-12. As part of our considerations related to this paragraph, we first considered that
Abacus and LMA are defined together as ‘the Companies’ in the Merger Agreement as the legal form of the transaction is that ERES is acquiring both LMA and Abacus. We next then considered whether ERES met any of the criteria under ASC
805-10-15-12 that could indicate that ERES could be acquirer. While ERES stockholders will receive between 27.68% and 30.49% of the voting rights depending on redemption scenarios (when factoring in the exercise of warrants), we also considered
other qualitative factors including the fact that they will only receive one board seat, will have no role in management, will not be retaining their name and will not be retaining their headquarters. When considering these factors in totality, ERES
was determined not to be the acquirer (consistent with a reverse recapitalization between a SPAC and target where neither entity is a VIE). Rather, the acquirer would be either LMA or Abacus as both companies could not be identified as the acquirer
and neither company was identified as a VIE.

 In identifying which entity would be identified as the acquirer, with a focus between Abacus
and LMA (having previously ruled out ERES as the accounting acquiror given the overall structure of the transaction as a reverse recapitalization but with two targets), we considered the guidance in ASC 805-10-55-12 through 55-13. Specifically, our considerations are included below:

 Guidance codification and summarized description

 Evaluation

ASC 805-10-55-12a: a. The relative voting rights in the combined entity after the business combination. The
acquirer usually is the combining entity whose owners as a group retain or receive the largest portion of the voting rights in the combined entity.

LMA and Abacus were acquired by ERES together. That is, the transaction was negotiated for the purchase of both entities. Given the overlap of the owners between the two entities (4 owners of LMA, 3 of whom are the owners of
Abacus), it is not clear which portion of equity granted to the former owners is by virtue of their ownership in one entity over the other. Accordingly, in considering the relative voting rights, we would point to the relative fair value of the
entities to determine the amount of the equity granted to the former owners (and therefore voting rights) related to each of the entities. This consideration would lead to LMA as the accounting acquirer as discussed further related to the relative
size of the entities below in paragraph 55-13.

ASC 805-10-55-12b: The existence of a large minority voting interest in the combined entity if no other owner or
organized group of owners has a significant voting interest. The acquirer usually is the combining entity whose single owner or organized group of owners holds the largest minority voting interest in the combined entity.

Each of the individual voting interest holders of Abacus and LMA retain an equal share of the voting interests in the combined entity at 25% each (that is, 25% of the 60-70% allocated to prior owners depending on redemption levels
upon close). The circumstances indicate this fact is inconclusive of the accounting acquirer.

ASC 805-10-55-12c: The composition of the governing body of the combined entity. The acquirer usually is the
combining entity whose owners have the ability to elect or appoint or to remove a majority of the members of the governing body of the combined entity.

The governing body will be the Board of Directors. The Board of Directors will comprise seven seats: one a former owner of both Abacus and LMA; one a former owner of only LMA; one an executive of ERES; and four who are required to
be independent (i.e., not nominated, appointed, or terminated by either party unilaterally). Because two seats are for former LMA owners, we believe that this criterion points to LMA over Abacus.

ASC 805-10-55-12d: The composition of the senior management of the combined entity. The acquirer usually is the
combining entity whose former management dominates the management of the combined entity.

The existing Companies’ senior management of LMA and Abacus will continue in their pre-transaction capacity as there are no redundancies between the two entities. The lack of change in
management indicates this fact is inconclusive of the accounting acquirer.

 December 7, 2022

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ASC 805-10-55-12e: The terms of the exchange of equity interests. The acquirer usually is the combining entity
that pays a premium over the pre-combination fair value of the equity interests of the other combining entity or entities.

Given the structure of the transaction, a premium is unknown and thus this is no