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CORRESP
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CORRESP

 Worldwide Webb Acquisition Corp.

770 E Technology Way

 Orem, Utah
84097

 September 13, 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.

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

Filed August 9, 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 September 1, 2023, with respect to the above referenced Amendment No. 1 to Registration Statement on Form S-4. Concurrently with the submission of this letter, the Company is filing
Amendment No. 2 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.

 Amendment No. 1 to Registration
Statement on Form S-4 Filed August 9, 2023

 Proxy Statement/Prospectus Cover Page, page
ii

1.
 Staff’s comment: 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.

 Response: The Company acknowledges the Staff’s comment
and respectfully advises the Staff that as a result of the transaction structure, the Sole Shareholder has no voting interests in ATI prior to exercising its exchange right pursuant to the AARK Exchange Agreement, despite having the largest economic
interest in ATI. See the table on page 16 of the Revised Registration Statement titled “Economic and Voting Interests in ATI (Pre-Exchange).” As described in our previous response and in
the Revised Registration Statement, the Class V Shareholder is owned by a business associate of the Sole Shareholder. Although the Class V Shareholder is not required by contract or otherwise to vote in a manner that is beneficial to the
Sole Shareholder and may vote the Class V ordinary share in its sole discretion, given the business relationship between the Class V Shareholder and the Sole Shareholder, the Sole Shareholder believes that the Class V Shareholder
could protect the interests of the Sole Shareholder from extraordinary events, such as a hostile takeover or board contest, prior to the exchange of AARK ordinary shares by the Sole Shareholder. The Class V Shareholder’s voting right will
be proportionately reduced in connection with the exchange of AARK ordinary shares by the Sole Shareholder because post-exchange, the Sole Shareholder will hold voting shares at ATI and can therefore protect its own interest in case of a hostile
takeover or board contest. As previously disclosed, the Class V Shareholder does not derive any economic benefit from holding the Class V ordinary share and will not receive any compensation in connection with its ownership of the
Class V ordinary share. The Sole Shareholder also will not derive any economic benefit or compensation from the Class V Shareholder due to this arrangement.

The Company has revised the disclosure on pages 13 and 153 of the Revised Registration Statement accordingly.

Questions and Answers for Shareholders of WWAC

 What
will the corporate structure of ATI be following the Business Combination, page 10

2.
 Staff’s comment: 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.

Response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that ATI controls
AARK immediately post transaction through control of the Board of Directors. Pursuant to paragraphs 55 and 56 of the Constitution of AARK (see Annex F of the Revised Registration Statement), the AARK board will have the authority to make

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all significant decisions related to the day-to-day operations of AARK. Pursuant to paragraph 47 of the
Constitution of AARK, as long as the Class V Share remains outstanding, the board of AARK will be comprised of three directors. Pursuant to paragraph 49 of the Constitution of AARK, ATI will have the right to nominate two of the three
directors, and such two directors will be selected only from the four independent directors of ATI (the “ATI director nominees”). Pursuant to Article 21.15 of the Proposed Memorandum and Articles of Association, the Sole Shareholder will
abstain from voting on the appointment of either of the two ATI director nominees.

 At the effective time of the
amalgamation, existing shares of AARK currently held by the Sole Shareholder will remain issued and outstanding, and additional shares of AARK will be issued to ATI, for consideration as described below. ATI’s and the Sole Shareholder’s
ownership interests in AARK are determined based on the pre-transaction equity value of Aeries, which is $349 million, and the number of shares converted is dependent on the available cash of WWAC after
redemptions and net of all WWAC liabilities, including unpaid transaction expenses. WWAC currently owns all of the shares of Amalgamation Sub, and these shares will be converted into AARK ordinary shares upon amalgamation, and will continue to be
held by ATI.

 The Company has revised the disclosure on the cover page and pages iii, viii, 7, 10, 33 and 95 of the Revised
Registration Statement accordingly.

3.
 Staff’s comment: 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.

 Response: The Company acknowledges the Staff’s comment and
has revised the disclosure on pages 10 and 154 of the Revised Registration Statement accordingly.

 Company Overview, page 30

4.
 Staff’s comment: 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).

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 Response: The Company acknowledges the Staff’s comment
and has revised the disclosure on pages 31, 197, 198 and 210 of the Revised Registration Statement accordingly.

 Exchange Agreements, page 41

5.
 Staff’s comment: 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.

 Response: The Company acknowledges the Staff’s comment
and has revised the disclosure on pages 43, 100, 124 and 154 of the Revised Registration Statement accordingly.

 Interests of WWAC’s Directors and
Executive Officers in the Business Combination, page 45

6.
 Staff’s comment: 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.

Response: The Company acknowledges the Staff’s comment and has revised the disclosure on page 49 and 50 of
the Revised Registration Statement to restore the sub-section titled “Sources and Uses of Funds for the Business Combination.”

Summary Unaudited Pro Forma Condensed Combined Statement of Operations Information for the Year Ended March 31, 2023, page 54

7.
 Staff’s comment: 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.

Response: The Company acknowledges the Staff’s comment and has revised the disclosure on page 56 of the
Revised Registration Statement to reflect the unaudited pro forma results for the six months ended June 30, 2023.

 Your unexpired warrants may be
redeemed prior to their exercise at a time that is disadvantageous to you, thereby significantly..., page 79

8.
 Staff’s comment: 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.

 Response: The Company acknowledges the Staff’s comment and has revised the disclosure
on page 82 of the Revised Registration Statement accordingly.

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 Description of the Business Combination, page 148

9.
 Staff’s comment: 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.

Response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that the
percentage of economic interests in AARK was determined on a pre-transaction equity value of Aeries of $349 million, AARK’s ownership of 85.31% of the issued and outstanding Aeries Shares, and the
other Aeries Holders’ 14.69% ownership of the issued and outstanding Aeries Shares and the number of shares of Amalgamation Sub that will automatically convert into AARK ordinary shares. Pursuant to the Amalgamation, all AARK ordinary shares
that are issued and outstanding prior to the the Effective Time will remain issued and outstanding following the Effective Time and continue to be held by the Sole Shareholder, and all of the shares of Amalgamation Sub that are issued and
outstanding as of the Effective Time will be automatically converted into a number of AARK ordinary shares dependent upon available cash of WWAC after redemptions and net of all WWAC liabilities, including WWAC unpaid transaction expenses. The
Combined Company will own these converted AARK ordinary shares directly, and the number of AARK ordinary shares to be issued in connection with the Amalgamation will be based on an assumed price of $10.10 per share. Based on this arrangement,
(i) assuming Minimum Redemptions, WWAC will acquire 34% of the economic interests in AARK while the Sole Shareholder and Aeries Holders will collectively retain 66% of the economic interests in AARK; (ii) assuming Medium Redemptions, WWAC
will acquire 33% of the economic interests in AARK while the Sole Shareholder and Aeries Holders will collectively retain 67% of the economic interests in AARK; and (iii) assuming Maximum Redemptions, WWAC will acquire 33% of the economic
interests in AARK while the Sole Shareholder and Aeries Holders will collectively retain 67% of the economic interests in AARK.

 The
Company has revised the disclosure on page 152 of the Revised Registration Statement accordingly.

 Notes to Unaudited Pro Forma Condensed Combined
Financial Statements

 Note 4—Net income per share, page 163

10.
 Staff’s comment: 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.

 Response: The Company acknowledges the
Staff’s comment. The Exchange Agreement between ATI, Aeries, and AARK provides that, from and after April 1, 2024, and subject to the satisfaction of the exercise conditions specified therein, the Exchanging Aeries Holders and the Sole
Shareholder will have the right to exchange their respective interests in Aeries and AARK for Class A ordinary shares of ATI. ASC
260-10-45-13 provides that shares issuable for little or no cash consideration upon the satisfaction of certain conditions
(contingently issuable shares) shall be considered outstanding common shares and included in the computation of basic earnings per share (“EPS”) as of the date that all necessary conditions have been satisfied
(in essence, when issuance of the shares is no longer contingent). As the necessary exercise conditions required for issuance of the underlying 34,554,454 Class A ordinary shares associated with the Exchange Agreement will not have been
satisfied at the time the Business Combination takes effect, the Company believes the shares should be excluded from basic EPS.

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 ASC 260-10-45-55 states that contingently issuable potential common shares (other than those covered by a contingent stock agreement, such as contingently issuable convertible securities) shall be included
in diluted EPS pursuant to the contingent share provisions in paragraphs 260-10-45-48 through
45-54. The guidance in ASC 260-10-45-48 provides that shares whose issuance is contingent
upon the satisfaction of certain conditions shall be considered outstanding and included in the computation of diluted EPS if all necessary conditions have been satisfied by the end of the period (the events have occurred).

In addition, the guidance in ASC 260-10-45-54 provides that if the contingency is based on a condition other than earnings or market price (for example, opening a certain number of retail stores), the contingent shares shall be
included in the computation of diluted EPS based on the assumption that the current status of the condition will remain unchanged until the end of the contingency period.

Exhibit C of the Exchange Agreement provides that the exchange of shares between ATI, Aeries, and AARK is subject to approval
from Reserve Bank of India and any other regulatory approvals, and the satisfaction of at least two of the six other conditions.

In accordance with ASC
260-10-45-54, if the contingency is based on a condition other than earnings or market price, the contingent shares shall be
included in the computation of diluted EPS based on the