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CORRESP
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CORRESP

 Worldwide Webb Acquisition Corp.

770 E Technology Way

 Orem, Utah
84097

 August 9, 2023

 VIA EDGAR

Attention:
 Abe Friedman

 Doug Jones

 Nicholas Nalbantian

 Lilyanna Peyser

United States Securities and Exchange Commission

 Division of
Corporation Finance

 Office of Trade & Services

 100
F Street, NE

 Washington, D.C. 20549

Re:
 Worldwide Webb Acquisition Corp.

 Registration Statement on Form S-4

 Filed May 12, 2023

 File No. 333-271894

Ladies and Gentlemen:

 This letter sets forth
the response of Worldwide Webb Acquisition Corp. (the “Company”) to the comments of the staff of the Division of Corporate Finance (the “Staff”) of the Securities and Exchange Commission set forth in
your letter dated June 11, 2023, with respect to the above referenced Registration Statement on Form S-4 (the “Registration Statement”). Concurrently with the submission of this
letter, the Company is filing Amendment No. 1 to the Registration Statement on Form S-4 (the “Revised Registration Statement”). Capitalized terms used but not otherwise defined
herein shall have the meanings ascribed thereto in the Registration Statement.

 Set forth below is the Company’s response to the
Staff’s comments. For the Staff’s convenience, we have incorporated your comments into this response letter in italics.

 Registration
Statement on Form S-4 Filed May 12, 2023

 Proxy Statement/Prospectus Cover Page, page ii

1.    Staff’s comment: Please disclose that the Class V Shareholder will control
at least 26%, and potentially 51%, of the voting power of the Combined Company. Supplementally provide us with your analysis as to whether the Combined Company will be a “controlled
company” under the Nasdaq listing rules.

 Response: The Company acknowledges the Staff’s comment
and has revised the disclosure on pages ii, 8,15, 33, 49, 51, 77, 86, 231 and 236 of the Revised Registration Statement accordingly.

 The
Company supplementally advises the Staff that we believe the Combined Company will be a “Controlled Company” under Nasdaq Listing Rule 5615(c), which states that a “Controlled Company” is “a Company of which more than 50% of
the voting power for the election of directors is held by an individual, a group or another company.” In the following circumstances, the total voting rights represented by the Class V ordinary share will increase automatically to 51% of
the total issued and outstanding Class A ordinary shares and Class V ordinary shares voting together as a class: (1) a Hostile Change of Control of, or a threat of a Hostile Change of Control of ATI (as such term is defined in the
Business Combination Agreement), or (2) the appointment or removal of a director on the Board of the Combined Company. Given the Class V shareholder’s 51% voting power of the Combined Company following the Business Combination for the
appointment or removal of a director on the board of the Combined Company, we believe the Company will be a “Controlled Company”. However, the Company currently does not plan to utilize the exemptions afforded to a “Controlled
Company” under the Nasdaq listing rules.

 Proxy Statement/Prospectus Cover Page, page ii

2.    Staff’s comment: Here and elsewhere you state the Class V Shareholder
is NewGen Advisors and Consultants DWC-LLC (“NewGen”). On page 226 you state the Class V ordinary share
may be issued only to the Sole Shareholder (that is Venu Kumar), its successors and assigns, as well as any permitted transferees of the Sole Shareholder. Please clarify for us and in the filing who the Class V
shareholder is. Also, clarify for us and disclose as appropriate if there is any relationship between Venu Kumar and NewGen and describe the relationship.

Response: The Company acknowledges the Staff’s comment and has revised the disclosure on pages 12, 150 and
242 of the Revised Registration Statement to clarify that only the Class V Shareholder can hold the Class V ordinary share, that the Class V Shareholder may not transfer the Class V ordinary share to any transferee and any
attempted transfer of the Class V ordinary share will be void. The Company has also revised the disclosure on pages 12, 94, 150 and 242 of the Revised Registration Statement to describe the relationship between NewGen and the Sole Shareholder,
and supplementally advises the Staff that the Class V share will be held by NewGen, which is owned by a business associate of the Sole Shareholder. The Sole Shareholder does not have ownership in or control of NewGen. NewGen does not derive any
economic benefit from such shareholding and will not receive any compensation in connection with its ownership of the Class V share.

 Dear
Worldwide Webb Acquisition Corp. Shareholders, page iii

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 3.    Staff’s comment: Here and
elsewhere you state after surviving the amalgamation AARK will become a subsidiary of ATI and the Sole Shareholder. Please explain to us how AARK can be a subsidiary of both. Also, explain to
us in detail what ownership interests are exchanged in this amalgamation and the amount of the interests held by each party in AARK after the amalgamation is completed. In particular, explain to us who owns the shares of
Amalgamation Sub that are automatically converted into AARK shares as stated in the second bullet on page 82 under “Business Combination Consideration.”

Response: The Company acknowledges the Staff’s comment and has revised the disclosure on pages iii, viii, 7,
32 and 93 of the Revised Registration Statement to clarify that AARK will be controlled by ATI and owned by ATI and the Sole Shareholder, until the Sole Shareholder exchanges its AARK ordinary shares for ATI Class A ordinary shares pursuant to
the AARK Exchange Agreement.

 Additional Information, page 3

4.    Staff’s comment: Please also state that the “other publicly available information”
includes important business and financial information about the company that is not included in or delivered with the document but is incorporated into the document. Refer to Item 2 of Form S-4.

 Response: The Company acknowledges the Staff’s comment and
has revised the disclosure on page 1 of the Revised Registration Statement accordingly.

 Questions and Answers for Shareholders of WWAC, page 6

 5.    Staff’s comment: Please revise to 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, 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 acknowledges the Staff’s comment and has revised the disclosure on pages 16 and 17 of
the Revised Registration Statement accordingly.

 What will the corporate structure of ATI be following the Business Combination?, page 8

6.    Staff’s comment: Please revise the second diagram to disclose the percentage ownership/voting
power of the identified groups of ATI shareholders assuming no and maximum redemptions. In addition, we note that “the Aeries Holders will retain a direct equity ownership in Aeries in the form of Aeries Shares” and the
Sole Shareholder will hold AARK ordinary shares; please revise the diagram to clarify the holdings of the Aeries Holders and the Sole Shareholder in each of the identified entities. Also
include the Class V Shareholder in the diagram.

 Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages 11 and 16 of the Revised Registration Statement accordingly.

 3

 What equity stake will current WWAC shareholders and current shareholders of Aeries hold in WWAC
immediately after the..., page 13

 7.    Staff’s comment: We note your inclusion of a
sensitivity analysis showing minimum and maximum redemption rates. Please revise your disclosure to also show the potential impact of redemptions on the per share value of the shares owned by non-redeeming
shareholders at an interim redemption level. Also revise footnote 4 to disclose that the Class V Shareholder will have 26% of the voting power of the combined company at closing.

Response: The Company acknowledges the Staff’s comment and has revised the disclosure on pages 15 and 16 of
the Revised Registration Statement accordingly.

 Summary of the Proxy Statement/Prospectus, page 27

8.    Staff’s comment: We note you provide discussion of your historical non-GAAP EBITDA results and EBITDA margins here, and on pages 177 and 189. When discussing these non-GAAP measures, please provide similar discussion of the
comparable GAAP measures with equal or greater prominence. Refer to Item 10(e)(1)(i)(A) of Regulation
S-K and Question 102.10 of our Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on
pages 30, 193, 194 and 206 of the Revised Registration Statement accordingly.

 Summary of Material Financial Analyses, page 37

9.    Staff’s comment: We note your disclosure of engaging CVA as a “Financial Advisor.” We
also note on page 89 that you engaged Roth Capital Partners, LLC and D.A. Davidson & Co. as capital markets advisors. Please revise to expand your disclosure regarding the role and
remuneration of each outside financial advisor. Refer to Item 4(b) of Form S-4.

Response: The Company acknowledges the Staff’s comment and has revised the disclosure on pages 37, 101
and 107 of the Revised Registration Statement accordingly.

 Interests of WWAC Directors and Executive Officers in the Business Combination, page 42

 10.    Staff’s comment: Please disclose clearly
that the sponsor and its affiliates can earn a positive rate of return on their investment, even if other WWAC shareholders experience a negative rate of return in the post-business combination company. Here, in Risk Factors and
elsewhere as appropriate, highlight the risk that WWAC’s directors and executive officers, as well as the sponsor and its affiliates, will benefit from the completion of a business combination and may be incentivized to complete an
acquisition of a less favorable target company or on terms less favorable to shareholders rather than liquidate. Revise the seventh bullet to quantify the amount of proceeds currently in the trust account. Revise the
opening paragraph to disclose the amount, in the aggregate, that the sponsor and its affiliates have at risk that depends on completion of a business combination. Disclose the percentage of sponsor and its affiliates’ total potential ownership
interest in the combined company, assuming exercise and conversion of all securities.

 4

 Response: The Company acknowledges the Staff’s comment
and has revised the disclosure on pages 17, 45, 46, 79, 113 and 235 of the Revised Registration Statement accordingly.

11.    Staff’s comment: It appears that your charter waived the corporate opportunities doctrine.
Please address this potential conflict of interest and whether it impacted your search for an acquisition target.

Response: The Company acknowledges the Staff’s comment and has revised the disclosure on page 39 of the
Revised Registration Statement accordingly.

 12.    Staff’s comment: 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 acknowledges the Staff’s comment and has revised the disclosure on pages 45 and 113 of
the Revised Registration Statement accordingly.

 Risk Factors, page 54

13.    Staff’s comment: Please highlight the material risks to public warrant holders, including
those arising from differences between the private placement and public warrants. Clarify whether recent common stock trading prices exceed the threshold that would allow the company to redeem public warrants. Clearly explain the steps, if any, the
company will take to notify all shareholders, including beneficial owners, regarding when the warrants become eligible for redemption.

Response: The Company acknowledges the Staff’s comment and has revised the disclosure pages 79 and 80 of the
Revised Registration Statement accordingly.

 14.    Staff’s comment: Disclose the material risks
to unaffiliated investors presented by taking Aeries public through a merger rather than an underwritten offering. These risks could include the absence of due diligence conducted by an underwriter that would be subject to liability for any material
misstatements or omissions in a registration statement.

 Response: The Company acknowledges
the Staff’s comment and has added a new risk factor that addresses the material risks to unaffiliated investors presented by taking Aeries public through a merger rather than an underwritten offering on pages 80 and 81 of the Revised
Registration Statement.

 Background to the Business Combination, page 87

15.    Staff’s comment: Please elaborate upon the content of the technical due diligence report on
Aeries.

 Response: The Company acknowledges the Staff’s comment and has revised the
disclosure on page 100 of the Revised Registration Statement accordingly.

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 Aeries Projected Financial Information, page 94

16.    Staff’s comment: Please explain why Aeries chose to present projections based upon only a two-year period.

 Response: The Company acknowledges the Staff’s
comment and has revised the disclosure on page 105 of the Revised Registration Statement accordingly.

17.    Staff’s comment: Please revise to discuss whether and how performance for the fiscal year
ended March 31, 2023, has differed compared to estimated results and explain the reason(s) for any differences in performance.

Response: The Company acknowledges the Staff’s comment and has revised the disclosure on pages 106 and 107
of the Revised Registration Statement accordingly.

 Unaudited Pro Forma Condensed Combined Financial Information Notes to Unaudited Pro Forma Condensed
Combined Financial Information Note 1 - Description of the Business Combination, page 144

18.    Staff’s comment: We note you determined WWAC to be the
accounting acquirer based on its ability to control the board of directors of AARK. Please provide us a detailed analysis in making this determination. In doing so, tell us
your consideration of the following factors:

•

 The ability of WWAC to effectively control the board of directors, considering the Class V
share will have 51% of all votes in the event of an extraordinary event, which paragraph 22.2 of the Amended and Restated Articles of Association of Aeries Technology, Inc (Annex E) includes a scenario where
management “seeks a seat on the Board of Directors of the Company when such candidacy is not endorsed by existing members of the Board of Directors,” noting the chairman of the board is the Class V shareholder.

•

 If significant decisions of the entity are made at the board of directors level.

•

 The period of time which WWAC will be able to control the board of directors considering the change in voting
interests subsequent to the exchange agreement.

•

 Consideration of substantive participating rights of the AARK shareholder.

•

 The risk factor on page 13 states management of Aeries will become the management of ATI. In the same risk
factors, it appears representatives of AARK and Aeries and their appointees will have the majority of the members of the ATI board.

•

 The post exchange table on page 15 indicates the Sole Shareholder of AARK (who is Venu Kamar, Chairman of and
majority shareholder in Aeries) and Exchanging Aeries Holders combined will own the majority of outstanding ATI ordinary shares.

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•

 Disclosures on pages 48, 74 and 111 of the concentration of voting control with