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    Sidley
    Austin LLP

    787
    Seventh Avenue

    New
    York, NY 10019

    +1
    212 839 5300

    +1
    212 839 5599 Fax

    AMERICA
    ● ASIA PACIFIC ●  EUROPE

    MHEINZ@SIDLEY.COM

    +1
    212 839 5444

October 24, 2023

VIA EDGAR SUBMISSION

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Conlon Danberg

    Katherine Bagley

    Jeanne Bennett

    Brian Cascio

    Re: Dune Acquisition Corporation

     Amendment No. 3 to Preliminary Proxy Statement on
                                            Schedule 14A

     Filed September 29, 2023

     File No. 001-39819

Ladies and Gentlemen:

This letter sets forth the
response of Dune Acquisition Corporation (“Dune” or the “Company”) to the comment
of the Staff (the “Staff”) of the Securities and Exchange Commission set forth in the Staff’s letter,
dated October 20, 2023, with respect to the Company’s Amendment No. 3 to the Preliminary Proxy Statement on Schedule 14A, filed
on September 29, 2023, File No. 001-39819 (the “Third Amended Proxy Statement”).

Concurrently with the submission
of this letter, we are publicly filing Amendment No. 4 to the Third Amended Proxy Statement (the “Fourth Amended Proxy Statement”)
in response to the Staff’s comment. Capitalized terms used but not otherwise defined herein shall have the meanings ascribed thereto
in the Fourth Amended Proxy Statement. For your convenience, the Staff’s comment is reprinted in bold below, followed by the Company’s
response thereto.

Sidley Austin (NY) LLP is a Delaware limited liability partnership
doing business as Sidley Austin LLP and practicing in affiliation with other Sidley Austin partnerships.

  U.S. Securities and Exchange Commission

October 24, 2023

Page 2

Amendment No. 3 to Preliminary Proxy Statement
on Schedule 14A, filed September 29, 2023

Opinion of Dune’s Financial Advisor

Discounted Cash Flow Analysis, page 115

1. We note your statement
that “The 2023 – 2032 forecast was one of multiple financial analyses used by Newbridge in connection with its opinion based
on guidance from Global Hydrogen.” Please expand on this statement to explain the other financial analyses Newbridge used in connection
with its opinion. Please note if the other financial analyses are disclosed in the proxy statement. To the extent the financial analyses
are not disclosed, please explain why you believe they are not required to be disclosed.

RESPONSE:

Upon further
consideration, in response to the Staff’s comment, the Company has deleted such statement in the Fourth Amended Proxy
Statement. The Company respectfully advises the Staff that the comparable public company analysis disclosed in “The
Business Combination Proposal — Opinion of Dune’s Financial Advisor — Comparable Public Company
Analysis” beginning on page 112 of the Fourth Amended Proxy Statement and the DCF Analysis disclosed in “The
Business Combination Proposal — Opinion of Dune’s Financial Advisor — Discounted Cash Flow
Analysis” beginning on page 113 of the Fourth Amended Proxy Statement were the only two financial analyses that Newbridge
used in connection with rendering its fairness opinion to the Dune Board of Directors. The Company has revised the Third Amended
Proxy Statement in response to the Staff’s comment. Please see pages 66, 112, 114 and 115 of the Fourth Amended Proxy
Statement.

*       *       *       *

If you have any questions
regarding the foregoing or the Fourth Amended Proxy Statement, please contact the undersigned at (212) 839-5444.

    Very truly yours,

    /s/ Michael P. Heinz

    Michael P. Heinz

    cc: Carter Glatt, Dune Acquisition Corporation

     Chief Executive Officer