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November 4, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Division of Corporation Finance

Office of Energy & Transportation

Washington, D.C. 20549

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

    Re:

    Swiftmerge Acquisition Corp.

    AleAnna Energy, LLC

    Amendment No. 1 to Registration Statement on Form S-4

    Filed October 8, 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 October
25, 2024, regarding the SPAC’s and the Company’s Amendment No. 1 to Registration Statement on Form S-4 (the “First Amended
Registration Statement”) filed with the Commission on October 8, 2024. In connection with this letter, an amendment to the Registration
Statement (the “Second 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.

Amendment No. 1 to Registration Statement on
Form S-4 filed on October 8,2024

Proxy Statement/Prospectus Summary

Dilution, page 37

    1.
    We note you disclose here and elsewhere in your proxy statement/prospectus the net tangible book value per share as adjusted for the following redemption scenarios – No Additional Redemptions, 50% Redemption Scenario, and Maximum Redemption. Please expand your disclosure to include a range of redemption scenarios that will reasonably inform investors of potential outcomes.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosures throughout the Second Amended Registration Statement to include
additional redemption scenarios in accordance with the Staff’s comment.

Risks Related to SPAC

BofA, as underwriters of the Initial Public Offering, was to be
compensated in part on a deferred basis in connection with the Initial, page 113

    2.
    We note your revised disclosure in response to prior comment 13. Please expand to disclose the reasons BofA agreed to waive its remaining deferred fees.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on pages 42, 113 and 159 of the Second Amended Registration Statement
accordingly.

SPAC does not have a specified maximum redemption threshold, page
116

    3.
    We note your revised disclosure in response to prior comment 15. Please expand your disclosure to discuss the impact that the trust falling below $5,000,001 may have on SPAC’s listing on Nasdaq or tell us why you believe this does not present a material risk.

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

Unaudited Pro Forma Condensed Combined Financial Information

Note 3 - Transaction Accounting Adjustments, page 127

    4.
    Refer to footnote 5 on page 127. We note you purchased two renewable natural gas plants in July 2024 and reflected these transactions as asset acquisitions within your pro forma financial statements. Based on your disclosure it appears you have not concluded on whether these acquisitions should have been accounted for and reflected within the proforma financial statements as business combinations under ASC 805. Please provide to us your accounting analysis for these two transactions.

Response:

ASC 805 defines a business as a set
of assets and activities that can be managed and conducted to provide economic benefits, lower costs, or dividends to owners, members,
participants, or investors. A business must have three key elements: inputs, processes, and outputs.
However, according to ASC 805, if substantially all of the fair value of the acquired assets is concentrated in a single identifiable
asset or a group of similar identifiable assets, the set is not considered a business and no further analysis is required.

Applying the Screen Test

ASC 805-10-55-5 provides a screen test,
which helps determine whether the acquired assets qualify as an asset acquisition rather than a business combination. If substantially
all of the fair value (typically 90% or more) of the gross assets acquired is concentrated in a single identifiable asset or a group of
similar identifiable assets, the acquisition is considered an asset acquisition.

For these acquired renewable natural
gas plants, the majority of the assets are concentrated in integrated Plant Assets, which includes anaerobic digestors, piping, electronic
controls, reciprocating generators, and other components physically connected and required for plant operation, and Land (where applicable).
This suggests that substantially all of the acquired assets are concentrated in a similar group of assets, supporting the view that the
acquisitions qualify as asset acquisitions. Further, the acquired renewable natural gas plants, in their current state, require upgrading
to transition from electricity production to renewable natural gas production and do not, in their present state, represent AleAnna’s
intended long-term highest and best use. As discussed on page 224 of the Second Amended Registration Statement, AleAnna intends to convert
the Plant Assets to biomethane production within a short time frame using “off-the-shelf” biogas (RNG) upgrading units.

    2

Campopiano Plant Asset Screen Test

Below is a summary of asset concentration
for the acquisition of the renewable natural gas plant known as the Campopiano plant, completed on July 29, 2024:

    Asset Categories
    Fair Value
    %

    Plant Assets
    $ 2,518,070
      63.70 %

    Land
      1,272,048
      32.18 %

    Automobiles
      162,666
      4.12 %

    Total
    $ 3,952,784
      100.00 %

As noted in the table above, over 95%
of the assets are concentrated in Plant Assets and Land, which significantly exceeds the “substantially all” threshold of
90% when viewed as a single asset. Management considered the following guidance in evaluating the Plant Assets (which includes anaerobic
digestors, piping, electronic controls, reciprocating generators, and other components physically connected and required for plant operation)
and Land as a single asset. ASC 805-10-55-5B states:

A single identifiable asset includes
any individual asset or group of assets that could be recognized and measured as a single identifiable asset in a business combination.
However, for purposes of this evaluation, the following should be considered a single asset:

a. A tangible asset that is attached
to and cannot be physically removed and used separately from another tangible asset (or an intangible asset representing the right to
use a tangible asset) without incurring significant cost or significant diminution in utility or fair value to either asset (for example,
land and building).

Management concluded that the Plant
Assets and the Land are considered a single identifiable asset for purposes of the screen test given the physical connectivity, and the
diminution in value of the renewable natural gas asset if separated from the group of physically connected Plant assets or the attached
Land.

Management also considered the qualitative
factors applied to the Casalino Plant above, in evaluating whether the acquisition represents an asset acquisition noting the following:

 ● The acquired set includes only a few assets (rather than multiple
asset classes)

 ● The acquired set does not include an organized workforce

    ●
    The acquired set does not include goodwill, nor would goodwill be expected in this type of acquisition

    ●
    The acquired set did not include a legal entity, nor any trademarks, customer lists, or similar identifiable intangibles

Based on the quantitative asset concentration
of 95% and the qualitative factors above, management concluded the Campopiano acquisition should be accounted for as an asset acquisition.

Casalino Plant Asset Screen Test

Below is a summary of the asset concentration
for the acquisition of the renewable natural gas plant known as the Casalino plant, completed on July 8, 2024:

    Asset Categories
    Fair Value
    %

    Plant Assets
    $ 3,160,425
      88.19 %

    Automobiles
      137,233
      3.83 %

    Inventory
      285,938
      7.98 %

    Total
    $ 3,583,595
      100.00 %

According to an interpretive guidance,
“substantially all” is generally considered to mean 90% or more but is not a bright line test. In the case of the Casalino
Plant, Plant Assets represent over 88% of the purchase price. Given the proximity to 90%, management also considered qualitative factors
in evaluating whether the acquisition represents an asset acquisition noting the following:

    ●
    The acquired set includes only a few assets (rather than multiple asset classes)

    ●
    The acquired set does not include an organized workforce

    ●
    The acquired set does not include goodwill, nor would goodwill be expected in this type of acquisition

    ●
    The acquired set did not include a legal entity, nor any trademarks, customer lists, or similar identifiable intangibles

Based on the quantitative and qualitative
factors above, Management concluded the Casalino acquisition should be accounted for as an asset acquisition.

    3

Conclusion

The acquisitions of the Casalino and
Campopiano renewable natural gas plants each qualify as asset acquisitions under ASC 805, based on the application of the screen test.
The purchase price of the acquired assets will be allocated pro-rata according to the estimated fair values of the acquired assets, with
no recognition of goodwill or bargain purchase gain. Direct transaction costs will be capitalized and depreciated over the useful lives
of the related assets.

We considered the impact an alternative
accounting treatment of the acquisitions as a business combinations on the unaudited pro forma financial information and future financial
statements of the Company. We note that if the acquisitions were accounted for as a business combination, no goodwill would be recognized
as the purchase price equates to the fair values of the acquired assets, and we have not identified any intangible assets or other major
asset classes. While the Casalino and Campopiano renewable natural gas plants represent processing capability (converting bio feedstocks
into electricity through reciprocating generators), the assets require independent sourcing of inputs, and do not have firm long-term
offtake contracts. Electricity is sold as produced to the regional electric utility under a tariff regime. Additionally, we note that
transaction costs would be expensed if business combination accounting were applied. Transaction costs are not material to the pro forma
financial information. Thus, accounting for the assets acquisitions as a business combination would not significantly alter the measurement,
presentation, or disclosure of the acquisitions in the unaudited pro forma financial information or future financial statements of the
Company.

Background to the Business Combination, page
156

    5.
    We note your revised disclosure in response to prior comment 22 and reissue the comment in part. Please revise your disclosure throughout this section to discuss in greater detail the material terms that were negotiated by the parties, how parties’ positions differed, and how issues were resolved. Your revised disclosure should disclose the initial pre-money valuation that was the basis for the consideration included in the letter of intent executed on April 1, 2024 that was later increased to $665,000,000 in the updated letter of intent and how the initial pre-money valuation was determined. In that regard, we note you disclose that AleAnna submitted the initial transaction terms by way of a draft non-binding letter of intent. In addition, please clarify the date the updated letter of intent was executed and discuss the negotiation of the board representation. To the extent certain terms were deemed not subject to negotiation, disclose this fact.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on pages 164 through 168 of the Second Amended Registration Statement
accordingly, including to clarify that no updated letter of intent was executed by the parties with respect to the terms of the letter
of intent that were renegotiated.

    6.
    We note your disclosure that SPAC management initially learned of AleAnna on or about March 11, 2024 from an affiliate of the sponsor of a special purpose acquisition company. However, your disclosure on page 164 states that Pureplay introduced SPAC to AleAnna in March 2024. Please advise or revise. In addition, please expand your disclosure to clarify Pureplay’s role in the business combination and any related negotiations.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on page 168 of the Second Amended Registration Statement accordingly.

    7.
    We note your revised disclosure in response to prior comment 23. We also note your disclosure that on or about September 20, 2024, Cohen entered into a release and termination agreement with SPAC, in which those parties agreed to reduce the advisory fee to which Cohen would be entitled upon closing of the Business Combination from $3,000,000 to $500,000. Please revise to clarify Cohen’s role regarding your business combination with AleAnna and related agreements and disclose the reason that Cohen agreed to reduce its advisory fee. 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 SPAC’s release and termination agreement with Cohen, 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 page 168 of the Second Amended Registration Statement accordingly.

    4

SPAC’s Valuation of AleAnna, page 170

    8.
    We note your disclosure regarding certain unaudited prospective information supplied by AleAnna to SPAC in connection with the proposed business combination, including the DeGolyer & MacNaughton reserves estimate and AleAnna’s RNG prospect backlog information. Please disclose whether or not AleAnna has affirmed to SPAC that its prospective information reflects its view about its future performance as of the most recent practicable date prior to the date of the proxy statement/prospectus. If the prospective information no longer reflect the views of AleAnna’s management or board of directors regarding its future performance as of the most recent practicable date prior to the date of the proxy statement/prospectus, clearly state the purpose of disclosing the prospective information and the reasons for any continued reliance by management or board of directors on the prospective information. Refer to Item 1609(c) of Regulation S-K.

Response: The Co-Registrants
acknowledge the Staff’s comment and have revised the disclosure on page 178 of the Second Amended Registration Statement accordingly.

    9.
    Please describe in greater detail the comparable companies analysis utilized to analyze AleAnna’s potential RNG