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    Sidley
    Austin LLP

    787
    Seventh Avenue

    New
    York, NY 10019

    +1
    212 839 5300

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    212 839 5599 Fax

    AMERICA
    ● ASIA PACIFIC ● EUROPE

May 3, 2024

VIA EDGAR SUBMISSION

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attention: Ruairi Regan and Brigitte Lippmann

 Re: Blue Ocean Acquisition Corp

Preliminary Proxy Statement on

Schedule 14A

Filed April 26, 2024

File No. 001-41112

Ladies and Gentlemen:

This letter is submitted on behalf of our
client, Blue Ocean Acquisition Corp (the “Company”), in response to a comment letter (the “Comment Letter”) addressed
to the Company, dated May 1, 2024, from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) with respect to the above referenced Preliminary Proxy Statement, filed on April 26,
2024 (the “Preliminary Proxy Statement”).

Set forth below are the Company’s
responses to the Comment Letter. For ease of reference, the comment contained in the Comment Letter is reproduced below in bold font type
and is immediately followed by the response of the Company.

The Company respectfully requests that the
Staff review the filed correspondence in advance of the Company filing its Definitive Proxy Statement on Schedule 14A (the “Definitive
Proxy Statement”).

Preliminary Proxy Statement on Schedule 14A filed April
26, 2024

General

1. COMMENT: We note your disclosure regarding The News Lens Co., Ltd. and your reference to the Form
8-K filed on June 6, 2023. Please clarify the current status of your merger with The News Lens Co., Ltd.

RESPONSE: The Company respectfully
acknowledges the Staff’s comment and advises the Staff that the Company and the other parties to the agreement and plan of merger
(the “Merger Agreement”), dated June 6, 2023, are working towards the satisfaction of the conditions to complete the proposed
transactions described therein, including the necessary filings with the Commission.

The Company is hereby submitting
marked pages set forth on Exhibit A hereto showing proposed changes to the Preliminary Proxy Statement.

U.S. Securities and Exchange Commission

May 3, 2024

Page 2

Risk Factors

We may not be able to complete an initial business combination...,
page 16

2. COMMENT: Please revise this risk factor to state clearly whether the SPAC’s sponsor is, is controlled
by, or has substantial ties with a non-U.S. person and disclose how this fact could impact your ability to complete your initial business
combination.

RESPONSE: The Company acknowledges
the Staff’s comment and is hereby submitting marked pages set forth on Exhibit B hereto showing proposed changes to the Preliminary
Proxy Statement.

*       *       *

Should you wish to discuss the foregoing response
at any time, please do not hesitate to contact me at (212) 839-5946 or at kterrero@sidley.com.

    Very truly yours,

    By:
    /s/ Kenny S. Terrero

    Kenny S. Terrero, Esq.

    cc:
    Richard Leggett – Blue Ocean Acquisition Corp.

    Stuart D. Karle – Blue Ocean Acquisition Corp.

U.S. Securities and Exchange Commission

May 3, 2024

Page 3

Exhibit A

The disclosure regarding The News Lens Co., Ltd. and references
to the Form 8-K filed on June 6, 2023 included in the Preliminary Proxy Statement will be revised in the Definitive Proxy Statement as
follows:

The purpose of the Extension Amendment Proposal
and, if necessary, the Adjournment Proposal, is to allow us additional time to complete an initial business combination and provide us
with additional flexibility to extend on a month-to-month basis the date by which we must complete an initial business combination. On
June 6, 2023, we entered into an Agreement and Plan of Merger (the “Merger Agreement”) with The News Lens Co., Ltd., a Cayman
Islands exempted company (“TNL”), and TNL Mediagene, a Cayman Islands exempted company and wholly owned subsidiary of TNL
(“Merger Sub”). Pursuant to the Merger Agreement, among other things, Merger Sub will merge with and into the Company, with
the Company surviving the merger as a wholly owned subsidiary of TNL (the “Proposed Transaction”).
For more information about the business combination with TNL, see our Current Report on Form 8-K filed with the U.S. Securities and Exchange
Commission (the “SEC”) on June 6, 2023. The Company
and the other parties to the Merger Agreement are working towards satisfaction of the conditions to complete the Proposed Transaction,
including the necessary filings with the SEC related to the Proposed Transaction, but have determined that there will not be sufficient
time before June 7, 2024. While we are using our best efforts to complete an initial business combination as soon as practicable,
the Board believes that there will not be sufficient time before the Termination Date to complete an initial business combination. Accordingly,
the Board believes that in order to be able to consummate an initial business combination, we will need to obtain the extension. Without
the extension, the Board believes that there is significant risk that we will not, despite our best efforts, be able to complete an initial
business combination on or before the Termination Date. If that were to occur, we would be precluded from completing an initial business
combination and would be forced to liquidate even if our shareholders are otherwise in favor of consummating an initial business combination.

U.S. Securities and Exchange Commission

May 3, 2024

Page 4

Exhibit B

The risk factor on page 16 of the Preliminary Proxy Statement will
be revised in the Definitive Proxy Statement as follows:

We may not be able to complete an initial business combination with
a U.S. target company if such initial business combination would be subject to U.S. foreign investment regulations and review by a U.S.
government entity such as the Committee on Foreign Investment in the United States (“CFIUS”), or is ultimately prohibited.

CFIUS is an interagency committee authorized
to review certain transactions involving foreign investment in the United States by foreign persons in order to determine the effect
of such transactions on the national security of the United States. We do not expect the Company to be considered
a “foreign person” under the regulations administered under CFIUS. However, entities that are “controlled” by
“foreign persons” may themselves be deemed to be “foreign persons” under the CFIUS regulations. Were
we considered to be a “foreign person” under such rules and regulations, any proposed business combination between us and
a U.S. business engaged in a regulated industry or which may affect national security could be subject to such foreign ownership restrictions
and/or CFIUS review. The scope of CFIUS was expanded by the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”)
to include certain non-controlling investments in sensitive U.S. businesses and certain acquisitions of real estate even with no underlying
U.S. business. FIRRMA, and subsequent implementing regulations that are now in force, also subject certain categories of investments
to mandatory filings.

The Sponsor has
substantial ties with non-U.S. persons but is not controlled by a non-U.S. person. The managers of the Sponsor, Marcus Brauchli and Richard
Leggett, are both U.S. citizens. Some of the members of the Sponsor are non-U.S. citizens or are controlled by a non-U.S. citizen. However,
such members have no management or control rights. While we do not believe any of the members that are non-U.S. citizens or are controlled
by a non-U.S. citizen would be deemed to control the Sponsor, if such a determination were made, and if CFIUS also determined that the
Sponsor controls the target of our initial business combination, CFIUS would have jurisdiction to review the business combination.

If our potential initial business combination
with a U.S. business falls within the scope of foreign ownership restrictions, we may be unable to consummate an initial business combination
with such business. In addition, if our potential business combination falls within CFIUS’s jurisdiction, we may be required to
make a mandatory filing or determine to submit a voluntary notice to CFIUS, or to proceed with the initial business combination without
notifying CFIUS and risk CFIUS intervention, before or after closing the initial business combination. CFIUS may decide to block or delay
our initial business combination, impose conditions to mitigate national security concerns with respect to such initial business combination
or order us to divest all or a portion of a U.S. business of the combined company if we proceeded without first obtaining CFIUS clearance.
The foreign ownership limitations, and the potential impact of CFIUS, may limit the attractiveness of a transaction with us or prevent
us from pursuing certain initial business combination opportunities that we believe would otherwise be beneficial to us and our shareholders.
As a result, the pool of potential targets with which we could complete an initial business combination may be limited and we may be
adversely affected in terms of competing with other special purpose acquisition companies which do not have similar foreign ownership
issues.

Moreover, the process
of government review, whether by CFIUS or otherwise, could be lengthy and we have limited time to complete our initial business combination.
If we cannot complete our initial business combination by June 7, 2024 (or December 7, 2024 if the period of time to consummate a business
combination is extended), because the review process extends beyond such timeframe or because our initial business combination is ultimately
prohibited by CFIUS or another U.S. government entity, we may be required to liquidate. If we liquidate, we cannot guarantee the per
share amount that our public stockholders will receive and our warrants will expire worthless. This will also cause you to lose the investment
opportunity in a target company and the chance of realizing future gains on your investment through any price appreciation in the combined
company.