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October 8, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Division of Corporation Finance

Officer of Energy & Transportation

Washington, D.C. 20549

Attention: Irene Barberena-Meissner, Karina Dorin,
Robin Babula and Gus Rodriguez

    Re:

    Swiftmerge Acquisition Corp.

    AleAnna Energy, LLC

    Registration Statement on Form S-4

    Filed July 5, 2024

    File No. 333-280699

Ladies and Gentlemen:

On behalf of Swiftmerge Acquisition
Corp. (the “SPAC”) and AleAnna Energy, LLC (the “Company”, together with the SPAC, the “Co-Registrants”),
below is the response of the SPAC and the Company to the comments of the staff of the Division of Corporation Finance (the “Staff”)
of the United States Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated August
6, 2024, regarding the SPAC’s and the Company’s Registration Statement on Form S-4 (the “Registration Statement”)
filed with the Commission on July 5, 2024. In connection with this letter, an amendment to the Registration Statement (the “Amended
Registration Statement”) has been submitted to the Commission on the date hereof.

For your convenience, the
Staff’s comments are set forth in bold, followed by responses on behalf of the SPAC and the Company. Unless otherwise indicated,
all page references in the responses set forth below are to the pages of the clean copy of the Amended Registration Statement.
Capitalized terms used but not otherwise defined herein shall have the meanings assigned to such terms in the Amended Registration Statement.

Registration Statement on Form S-4 filed on
July 5, 2024

Cover Page

    1.
    Please expand your disclosure to clarify that Nautilus Member will hold 93.2% of the voting power (assuming no Redemptions Rights are exercised) of outstanding Surviving PubCo Common Stock.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on the cover page and throughout the Amended Registration Statement
accordingly.

    2.
    Please revise your disclosure here and in your proxy statement/prospectus summary regarding compensation received by Sponsor to disclose the founder shares issued to sponsor and its affiliates and the amount paid for such shares. Also revise to disclose the aggregate amount paid and to be paid to Sponsor or an affiliate of Sponsor in connection with the monthly fee of up to $1,000 for office space, administrative and support services. Refer to Items 1604(a)(3) and 1604(b)(4) of Regulation S-K.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on the cover page and throughout the Amended Registration Statement
accordingly.

    U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

October 8, 2024

Page 2

    3.
    Please revise your disclosure here, in your proxy statement/prospectus summary, and elsewhere as appropriate in your filing, to address whether the target company officers or directors have any actual or potential material conflicts of interest, including any material conflict of interest that may arise in determining whether to proceed with the business combination, with unaffiliated security holders of the SPAC. Refer to Items 1603(b), 1604(a)(4), and 1604(b)(3) of Regulation S-K.

Response:

The Co-Registrants acknowledge the Staff’s
comment and have revised the disclosure on the cover page and throughout the Amended Registration Statement accordingly. The Co-Registrants
do not believe that AleAnna or any of its directors or officers have any actual or potential material conflicts of interest with unaffiliated
security holders of the SPAC with respect to the Business Combination, including whether to proceed with the Business Combination, or
the approval of the Required SPAC Proposals.do not believe that any of its directors .

    4.
    We note your disclosure on page 25 indicating that pursuant to the A&R Sponsor Letter Agreement, the Sponsor Related Parties have agreed to vote the SPAC Ordinary Shares owned by them representing 44.9% of the issued and outstanding SPAC Ordinary Shares in favor of the SPAC Proposals. You further disclose that additionally, pursuant to the Investor Letter Agreements, the Investors have agreed to vote an aggregate of 1,470,994 SPAC Class A Ordinary Shares and 2,250,000 SPAC Class B Ordinary Shares owned by them, representing approximately 54.4% of the issued and outstanding SPAC Ordinary Shares and 100% of the issued and outstanding SPAC Class B Ordinary Shares, in favor of the SPAC Proposals. As it appears that shareholder approval of the proposed domestication, business combination and other SPAC Proposals will be assured assuming the parties that executed voting agreements vote as indicated, please revise your disclosure here and throughout to proxy statement/prospectus to state so explicitly. If you believe shareholder approval is not assured, please explain why.

Response: The Co-Registrants acknowledge the Staff’s comment and have revised
the disclosure on the page v and throughout the Amended Registration Statement accordingly.

Selected Definitions, page 6

    5.
    Please expand your list of definitions to include additional industry oil and gas terms, e.g., developed reserves, developed acres, undeveloped acres, development well, exploratory well, extension well, gross well or acre, net well or acre, probable reserves, possible reserves, productive well, and unproved reserves.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on page 15 of the Amended Registration Statement accordingly.

Questions and Answers About the Business Combination
and the Extraordinary General Meeting Q. What happens if the Business Combination is not completed?, page 23

    6.
    We note your disclosure here and on page 92 indicates that December 17, 2025 marks 36-months from the date of effectiveness of the registration statement for your initial public offering. As the registration statement for your initial public offering was declared effective on December 14, 2021, it appears the 36-month mark would be December 14, 2024. Please advise or revise.

Response: The
Co-Registrants acknowledge the Staff’s comment and have revised the disclosure on page 26 and 104 of the Amended Registration
Statement accordingly.

    U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

October 8, 2024

Page 3

Q. May the Sponsor, SPAC’s directors,
officers, advisors or their affiliates purchase shares in connection with the Business Combination?, page 28

    7.
    We note your disclosure that the Sponsor and SPAC’s directors, officers, advisors or their affiliates may purchase SPAC Ordinary Shares in privately negotiated transactions or in the open market either prior to or after the Closing, including from SPAC Public Shareholders who would have otherwise exercised their Redemption Rights. We further note your disclosure that any such privately negotiated purchases may be effected at purchase prices that are in excess of the per-share pro rata portion of the aggregate amount then on deposit in the Trust Account. Please provide your analysis on how such potential purchases would comply with Rule 14e-5. To the extent that you are relying on Tender Offer Rules and Schedules Compliance and Disclosure Interpretation 166.01 (March 22, 2022), please provide an analysis regarding how it applies to your circumstances.

Response: The
Co-Registrants acknowledge the Staff’s comment and have revised the disclosure on pages 30 and 31 of the Amended Registration
Statement accordingly.

Proxy Statement/Prospectus Summary, page 31

    8.
    Revise the filing to provide the dilution disclosures required by Item 1604(c) of Regulation S-K.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on pages 37 and 140 of the Amended Registration Statement accordingly.

Structure of Surviving PubCo Immediately After
the Closing, page 31

    9.
    Please revise the diagram to disclose the ownership percentages held by the applicable shareholder groups in Surviving PubCo and HoldCo.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on pages 38 and 141of the Amended Registration Statement accordingly.

Risk Factors

Since we have no operating history related
to the production of natural gas assets, investors have no basis to evaluate, page 57

    10.
    Please revise your risk factor disclosure here and elsewhere as appropriate to clearly state that AleAnna is currently in the development stage and has not generated any revenue from its operations to date.

Response: The
Co-Registrants acknowledge the Staff’s comment and have revised the disclosure on pages 34, 71 and 218 of the Amended
Registration Statement accordingly.

    U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

October 8, 2024

Page 4

The market price of Surviving
PubCo Class A Common Stock could be adversely affected by sales of substantial amounts of Surviving PubCo, page 79

    11.
    Please revise to quantify the number of shares subject to registration rights pursuant to the A&R Registration Rights Agreement.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on pages 41 and 91 of the Amended Registration Statement accordingly.

If SPAC is deemed to be an investment company
under the Investment Company Act, SPAC may be required to institute burdensome, page 98

    12.
    Please revise to disclose that if you are found to be operating as an unregistered investment company, you may be required to change your operations or wind down your operations. Also include disclosure with respect to the consequences to investors if you are required to wind down your operations as a result of this status, such as the losses of the investment opportunity in a target company and any price appreciation in the combined company, and any warrants, which would expire worthless.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on page 111 of the Amended Registration Statement accordingly.

BofA, as underwriters of the Initial Public
Offering, was to be compensated in part on a deferred basis in connection with the Initial, page 101

    13.
    We note your disclosure here and elsewhere that on November 7, 2022, BofA entered into a letter agreement pursuant to which BofA agreed to irrevocably waive its entitlement to its remaining deferred discount to be paid pursuant to that certain Underwriting Agreement, dated December 14, 2021, by and between SPAC and BofA entered into in connection with SPAC’s IPO. Please expand your disclosure to discuss whether there were any disagreements or objections made to the disclosure in the filing. Also, address the material impact, if any, of agreement provisions that survive the fee waiver, such as indemnification, contribution, rights of first refusal or lockups.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on pages 41, 113 and 156 of the Amended Registration Statement accordingly.

    U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

October 8, 2024

Page 5

Our ability to complete the Business
Combination may be impacted if the Business Combination is subject to U.S. foreign investment, page 103

    14.
    We note your disclosure that “Sponsor is not ‘controlled’ (as defined in 31 CFR 800.208) by a foreign person, such that the Sponsor’s involvement in the Business Combination would be a “covered transaction” (as defined in 31 CFR 800.213).” Please revise to more clearly tell us whether your sponsor is, is controlled by, has any members who are, or has substantial ties with, a non-U.S. person. Please also tell us whether anyone or any entity associated with or otherwise involved in the transaction, is, is controlled by, has any members who are, or has substantial ties with, a non-U.S. person. Lastly, in your discussion of the consequences of liquidation to SPAC securityholders, also address that the warrants held by them would expire worthless.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on page 115 of the Amended Registration Statement accordingly.

SPAC does not have a specified maximum redemption
threshold., page 104

    15.
    Please expand your disclosure here and elsewhere as appropriate to discuss the impact that not having a specified maximum redemption threshold may have on SPAC’s securities being deemed a penny stock and listing on Nasdaq.

Response: The Co-Registrants acknowledge the Staff’s comment and have revised
the disclosure on pages 116 and 117 of the Amended Registration Statement accordingly.

Unaudited Pro Forma Condensed Combined Financial
Information

Note 1 - Description of the Business Combination,
page 114

    16.
    You disclose on page 114 that Footnote (f), “Excludes 11,250,000 shares of Surviving PubCo Class A Common Stock issuable upon the exercise of the SPAC Public Warrants.” However, within the table above you refer to footnote (6). Please correct this inconsistency.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on page 126 of the Amended Registration Statement accordingly.

Note 3 - Transaction Accounting Adjustments,
page 115

    17.
    You disclose that you are still evaluating the accounting for the Blugas Settlement agreement in footnote (6). Please tell us the accounting options you are evaluating, the relevant U.S. GAAP for these options, how the payment to settle the claim to future gas production provides probable economic value and whether any changes are necessary to your pro forma financial statements.

Response: As the Blugas Settlement
occurred on May 28, 2024, the Company has since concluded on the accounting for this transaction and recorded it in its condensed consolidated
interim financial statements as of and for the six months ended June 30, 2024 included in the Amended Registration Statement.

As disclosed in the condensed consolidated
interim financial statements as of and for the six months ended June 30, 2024, and elsewhere in the Amended Registration Statement, the
Company accounted for the Blugas Settlement as the acquisition of Blugas’ interest in the future gas production, with $5.4 million
(the “Purchase Price”) included in natural gas and other properties and $1.2 million (the “VAT Portion”) included
in value-added tax refund receivable.

    U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

October 8, 2024

Page 6

The Company accounted for the acquisition
as an asset acquisition, in accordance with the guidance in ASC 932-360 and the general guidance in ASC-360 regarding the purchase of
properties. As the Blugas Settlement resulted in the Company acquiring Blugas’s 20% interest in the gas reserves, effectively transferring
ownership of this interest to the Company, the Purchase Price was capitalized to natural gas and other properties in the condensed consolidated
balance sheet, with the VAT Portion being included in value-added tax refund receivable.

This interest, an overriding royalty
interest (ORRI) whereby Blugas had claim to the first 350 million cubic meters of gas extracted, represents a tangible economic asset
with probable future economic benefits as it grants the Company the right to a proportionate share of the future gas production, which
can be sold in the market, thereby generating future cash flows. The Company’s year-end December 31, 2023 reserve quantities included
the 20% of 350 million stand