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September 1, 2023
Daniel Webb
Chief Executive Officer/Chief Financial Officer
Worldwide Webb Acquisition Corp.
770 E Technology Way F13-16
Orem, UT 84097
Re:Worldwide Webb Acquisition Corp.
Amendment No. 1 to Registration Statement on Form S-4
Filed August 9, 2023
File No. 333-271894
Dear Daniel Webb:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our June 11, 2023 letter.
Amendment No. 1 to Registration Statement on Form S-4, Filed August 9, 2023
Proxy Statement/Prospectus Cover Page, page ii
1.We note your response to comment 2 that the Class V Shareholder is owned by a business
associate of the Sole Shareholder and that the Sole Shareholder does not have ownership
in or control over the Class V Shareholder.  We further note that the number of votes
attributed to the Class V share is impacted by exchanges of AARK ordinary shares held
by the Sole Shareholder.  Please explain and disclose the reason for this interaction, the
purpose and reasoning for this relationship between the Class V Shareholder and the Sole
Shareholder, and the purpose and reasoning for this equity structure.

 FirstName LastNameDaniel Webb
 Comapany NameWorldwide Webb Acquisition Corp.
 September 1, 2023 Page 2
 FirstName LastName
Daniel Webb
Worldwide Webb Acquisition Corp.
September 1, 2023
Page 2
Questions and Answers for Shareholders of WWAC
What will the corporate structure of ATI be following the Business Combination, page 10
2.You state ATI controls AARK after the amalgamation.  Please explain to us in detail how
ATI controls AARK, particularly in view of that ATI controls 39.89% of AARK and the
AARK Sole Shareholder owns 60.11% of AARK.  Tell us the consideration exchanged
between the parties in the amalgamation that evidences the combination and how this
control occurs.  In particular, explain to us how ATI's equity in Amalgamation Sub
converts into AARK ordinary shares and the party or parties that hold(s) these AARK
shares.  Further, explain to us how the respective ATI and Sole Shareholders ownership
interests in AARK are determined.  In connection with the preceding, explain to us how
the combined company will own these converted AARK ordinary shares as disclosed at
the top of page 94.
3.Currently you show two diagrams, both post-business combination, with the distinction
between them being before and after the Sole Shareholder and the Aeries holders'
exchanges. Please add an additional diagram to show the structure before the business
combination in order to illustrate the formation of ATI from WWAC. Similarly to how
you have done so with the current diagrams, please provide explanatory footnotes to
depict any consideration exchanged or received by each party in the combination and
depict the ownership interests before and after the business combination.
Summary of the Proxy Statement/Prospectus
Company Overview, page 30
4.We note your revisions in response to comment 8.  Please note the most directly
comparable GAAP measure to your non-GAAP measures "EBITDA" and "adjusted
EBITDA is net "net income."  Refer to Question 103.02 in our "Non-GAAP Financial
Measures" Compliance and Disclosure Interpretations.  Additionally, your comparable
GAAP measures should precede mention of your non-GAAP measures.  Further, you state
Aeries has been EBITDA positive since 2013.  State the comparative GAAP measure over
this period of time.  Revise disclosures here and elsewhere as appropriate (e.g., pages 193
and 206).

 FirstName LastNameDaniel Webb
 Comapany NameWorldwide Webb Acquisition Corp.
 September 1, 2023 Page 3
 FirstName LastName
Daniel Webb
Worldwide Webb Acquisition Corp.
September 1, 2023
Page 3
Related Agreements
Exchange Agreements, page 41
5.It appears the first bullet represents WWAC's call option and the second bullet represents
the put option of AARK and Aeries shareholders.  If true, please clarify this here and
elsewhere similarly discussed.  Otherwise, it is not clear between the two bullets which
party may elect the Cash Exchange Payment that would need clarification.
Interests of WWAC's Directors and Executive Officers in the Business Combination, page 45
6.We note that in this amendment, you have removed the sub-section titled "Sources and
Uses of Funds for the Business Combination." Please restore this disclosure, or explain
why it was removed.
Summary Unaudited Pro Forma Condensed Combined Financial Information
Summary Unaudited Pro Forma Condensed Combined Statement of Operations Information for
the Year Ended March 31, 2023, page 54
7.The amounts presented here appear to reflect the unaudited pro forma results for the three
months ended March 31, 2023, as presented in the unaudited pro forma condensed
combined financial information.  Please revise as appropriate.
Your unexpired warrants may be redeemed prior to their exercise at a time that is
disadvantageous to you, thereby significantly..., page 79
8.We note your response to comment 13 and reissue in part. Please explain the steps, if any,
the company will take to notify all shareholders, including beneficial owners, regarding
when the warrants become eligible for redemption. If there is no process in place to notify
all shareholders, please disclose as much.
Unaudited Pro Forma Condensed Combined Financial Information
Description of the Business Combination, page 148
9.Please explain to us and disclose how the percentage of economic interests in AARK
for each redemption scenario in the first paragraph hereunder was determined.
Notes to Unaudited Pro Forma Condensed Combined Financial Statements
Note 4 - Net income per share, page 163
10.Refer to your response to comment 20.  Please explain to us your consideration of
reflecting the shares associated with the Exchange Agreement in the denominator of the
basic and/or diluted earnings per share computation as contingently issuable potential
common shares pursuant to ASC 260-10.

 FirstName LastNameDaniel Webb
 Comapany NameWorldwide Webb Acquisition Corp.
 September 1, 2023 Page 4
 FirstName LastName
Daniel Webb
Worldwide Webb Acquisition Corp.
September 1, 2023
Page 4
Solutions We Offer, page 196
11.We note your response to comment 24 and reissue in part. Please revise your new
disclosure to define technical terms and industry jargon after the first instance that they
are used such as “NLP engine,” “L1, L2 IT Services” and “L3/L4 issues.”
Innovation Labs, page 198
12.We note additional disclosure in this proxy statement adding details to the bullets labeled
"Intelligent ESG," "Health AI," Social Behavior AI," and "Cyber Intelligence." Please
make clear in each of these bullet points, if true, that these are not yet products or services
Aeries provides, and are instead areas of research or are aspirational. For example, please
make clear whether Aeries is currently using "Health AI" to diagnose user diseases as a
service.
Aeries' Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 209
13.Your adjustment for "Other Income (expense), net" is not appropriate in arriving at
"EBITDA."  Refer to Question 103.01 of our "Non-GAAP Financial Measures"
Compliance and Disclosure Interpretations for guidance.  Please revise your computation
accordingly.  Also revise your disclosures wherever this measure is discussed in your
filing.
Beneficial Ownership of Securities, page 235
14.We note your response to comment 31 and reissue in part. Please also revise to clarify
which portion of the holdings prior to the Business Combination are comprised of Class A
or Class B ordinary shares.
Description of ATI Securities
Certain Differences in Corporate Law, page 251
15.We note your response to comment 32. To the extent WWAC and Aeries have executive
officers in other jurisdictions, such as the UAE or Singapore, please further revise this
disclosure accordingly.
General
16.We note changes made throughout the proxy statement that have amended the description
of the post-combination status of AARK from a subsidiary of ATI and the Sole
Shareholder, to "controlled by ATI." However, your new disclosure also states that at
Closing, ATI will own 39.89% of AARK. Please clarify how ATI will "control" AARK if
the ownership stake will be 39.89% from the Closing Date until April 1, 2024, when the
Exchange Agreements would allow the Sole Shareholder to have the right to exchange
AARK ordinary shares for ATI ordinary shares. In addition, in other portions of the proxy

 FirstName LastNameDaniel Webb
 Comapany NameWorldwide Webb Acquisition Corp.
 September 1, 2023 Page 5
 FirstName LastName
Daniel Webb
Worldwide Webb Acquisition Corp.
September 1, 2023
Page 5
statement you state that AARK will be "partially owned" by ATI, rather than controlled.
Please clarify this discrepancy.
17.We note your response to comment 12.  Please also quantify the value of warrants, based
on recent trading prices, that may be retained by redeeming stockholders other than
directors and executive officers assuming maximum redemptions and identify any
material resulting risks.
            You may contact Abe Friedman at 202-551-8298 or Doug Jones at 202-551-3309 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Nalbantian at 202-551-7470 or Lilyanna Peyser at 202-551-3222 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lance Hancock