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CORRESP
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 ArentFox Schiff LLP
 1717 K Street NW
 Washington, DC 20006

 202.857.6000 main
 202.857.6395 fax

 afslaw.com

 Ralph De Martino
 Partner
 (202) 724-6848 direct
 rdemartino@afslaw.com

 April 3, 2025

 Office of Industrial Applications and Services

 Division of Corporation Finance

 United States Securities and Exchange Commission

 100 F St NE

 Washington, DC 20549

 Attention:
 Jane Park

 Katherine Bagley

 Re:

 NorthView Acquisition Corporation
 Amendment No. 10 to Registration Statement on Form S-4
 Filed February 12, 2025
 File No. 333-269417

 To Whom It May Concern:

 The undersigned submits this letter on behalf
of NorthView Acquisition Corporation ("NorthView") and Profusa, Inc. ("Profusa" and together with NorthView, the
"Co-Registrants"). Contemporaneous with the submission of this correspondence, NorthView filed its Amendment No. 11 (the "Amendment")
to its Registration Statement on Form S-4 (File No. 333-269417). Pursuant to the comments by the staff (the "Staff") of the
Division of Corporation Finance of the United States Securities and Exchange Commission (the "Commission"), set forth in its
letter dated March 7, 2025 (the "Comment Letter"), and addressed to Jack Stover, Chief Executive Officer of NorthView, and
Ben Hwang, Chief Executive Officer of Profusa, the Amendment responds to the Staff's comments included in the Comment Letter. For
the convenience of the Staff, the comments included in the Comment Letter are posted below (in bold) and NorthView's response follows
each comment.

 Amendment No. 10 to Registration Statement on Form S-4 filed
February 12, 2025 Cover Page

 1. We refer to your cover page disclosure relating to the material conflicts of interest in connection
with the de-SPAC transaction. Please revise your cover page to discuss any actual or potential sources of conflicts of interest between
the target company's officers and directors and the unaffiliated security holders as required by Item 1604(a)(4) of Regulation S-K.
Please make conforming changes to the Summary section. Refer to Item 1604(b)(3).

 Response : The Co-Registrants acknowledge the Staff's comment and have revised
the disclosure on the cover page and pages 7 and 16 of the Amendment.

 2. We note your disclosure that "NorthView's shares of Common Stock, public warrants and rights
are currently quoted on OTC Pink," and that upon consummation of the Business Combination, "New Profusa's shares of Common Stock
and public warrants will be listed on the Nasdaq Capital Market." Please revise to clarify, as you do on page 76, that in connection
with the business combination, you will be required to demonstrate compliance with Nasdaq's initial listing requirements in order to be
listed on Nasdaq.

 Response : The Co-Registrants
acknowledge the Staff's comment and have revised the disclosure on the cover page of the Amendment.

 Jack Stover NorthView Acquisition Corporation April 3, 2025 Page 2

 Summary of the Proxy Statement/Prospectus, page 1

 3. We refer to your disclosure on page 9 that the NorthView Board has determined that the business
combination is in the best interests of its shareholders. Please revise your Summary disclosure to describe any material factors that
the NorthView Board considered in making this determination, including any report, opinion, or appraisal. Refer to Item 1604(b)(2) of
Regulation S-K.

 Response : The Co-Registrants
acknowledge the Staff's comment and have revised the disclosure on page 10 of the Amendment.

 4. Please revise the Summary to provide a brief description of the material financing transactions
that have occurred or will occur in connection with the consummation of the de-SPAC transaction, the anticipated use of proceeds from
these financing transactions and the dilutive impact, if any, of these financing transactions on non- redeeming shareholders. We refer
to your disclosure on the cover page. Refer to Item 1604(b)(5) of Regulation S-K.

 Response : The Co-Registrants
acknowledge the Staff's comment and have revised the disclosure on pages 9 and 10 of the Amendment.

 5. Please revise your disclosure to address the following comments relating to NorthView's Sponsor:

 ● Please revise to include a description of the general character
of the NorthView Sponsor's business, where appropriate. Refer to Item 1603(a)(2) of Regulation S-K;

 ● Please revise to describe the experience of NorthView's Sponsor, its affiliates, and any promoters
in organizing SPACs. Refer to Item 1603(a)(3); and

 ● Please revise to identify the controlling persons of NorthView's Sponsor and disclose, as
of the most recent practicable date, the persons who have direct and indirect material interests in NorthView's Sponsor, as well
as the nature and amount of their interests. Refer to Item 1603(a)(7).

 Response : The Co-Registrants
acknowledge the Staff's comment and have revised the disclosure on pages vii, 8 and 9 of the Amendment.

 Interests of Certain Persons in the Business Combination, page
7

 6. We note your disclosure on pages 74 and 217 of NorthView's executive officers and directors'
other fiduciary duties or contractual obligations, other than with respect to NorthView and/or the Sponsor. Please revise to disclose
any material interests held by the target company's officers or directors that consist of any interest in, or affiliation with,
the Sponsor or the SPAC. Refer to Item 1605(d) of Regulation S-K.

 Response : The Co-Registrants
acknowledge the Staff's comment and have revised the disclosure on pages 76 and 219 of the Amendment.

 PIPE Transaction, page 18

 7. Pursuant to the PIPE Subscription, the PIPE Investors are expected to provide a loan to NorthView
in an aggregate principal amount of up to $22.2 million for a purchase price of up to $20 million, net after a 10% OID. The PIPE Subscription
contemplates purchasing these notes across multiple tranches. It is not clear how you arrived at the amount of $20 million. In this regard,
the amounts listed in your disclosures per each tranche appear to total up to more than $20 million. Please clarify your disclosures.
In addition, please address which PIPE tranches should be reflected in your pro forma financial statements and why.

 Response : The Co-Registrants
acknowledge the Staff's comment and have revised the disclosure on pages 19, 20 and 259 of the Amendment.

 Jack Stover NorthView Acquisition Corporation April 3, 2025 Page 3

 The Background of the Business Combination, page 116

 8. Please revise your disclosure, where appropriate, to discuss both the benefits and detriments of
the business combination and any related financing transactions to NorthView, the NorthView Sponsor, Profusa and public stockholders.
The benefits and detriments of the business combination and any related financing transaction must be quantified to the extent practicable.
Refer to Item 1605(c) of Regulation S-K.

 Response : The Co-Registrants acknowledge the Staff's comment and have revised
the disclosure on pages 117 and 118 of the Amendment.

 9. We note your disclosure that the Incentive Equity Value is expected to be $29,018,330 for purposes
of this prospectus. We also refer to your disclosure on page 18 relating to the PIPE transaction with Ascent Partners Fund LLC. Please
revise your background of the business combination section to include a detailed discussion of the negotiation of the Incentive Equity
Value and the PIPE transaction. In your revised disclosure, please explain the reason for Incentive Equity Value, how the terms of the
PIPE transaction were determined, the proposals and counter-proposals made during the course of negotiations, and how you reached agreement
on the final terms, as applicable.

 Response : The Co-Registrants
acknowledge the Staff's comment and have revised the disclosure on pages 134 through 137 of the Amendment.

 10. Please revise to state whether a majority of the directors (or members of similar governing body)
who are not employees of NorthView has retained an unaffiliated representative to act solely on behalf of unaffiliated security holders
for purposes of negotiating the terms of the de-SPAC transaction or preparing a report concerning the approval of the de-SPAC transaction.
Please refer to Item 1606(d) of Regulation S-K.

 Response : The Co-Registrants
acknowledge the Staff's comment and have revised the disclosure on page 161 of the Amendment.

 Opinion of Marshall & Stevens, page 130

 11. Please revise your disclosure to describe any material relationship that existed during the past
two years or is mutually understood to be contemplated between NorthView, the NorthView Sponsor and/or their respective affiliates and
Marshall & Stevens. Refer to Item 1607(b)(4) of Regulation S-K.

 Response : The Co-Registrants
acknowledge the Staff's comment and have revised the disclosure on page 140 of the Amendment.

 Jack Stover NorthView Acquisition Corporation April 3, 2025 Page 4

 Material U.S. Federal Income Tax Considerations, page 161

 12. Please revise to provide the federal income tax consequences of the de-SPAC transaction to (i) the
SPAC, (ii) the target company, (iii) target security holders, and (iv) SPAC security holders. Refer to Item 1605(b)(6) of Regulation S-K.
Please make conforming changes throughout your filing, including to your Questions and Answers on page xiii.

 Response : The Co-Registrants
acknowledge the Staff's comment and have revised the disclosure on pages 168 through 174 of the Amendment.

 Unaudited Pro Forma Financial Information, page 168

 13. We remind you of your response to comment 7 in your letter dated March 29, 2024 in which you indicated
that you were finalizing your analysis of Milestone III as far as whether or not the Milestone continues to be "indexed to the Company's
own stock." You indicated that you would include any related accounting impacts and disclosure requirements resulting from the analysis
and final conclusions in a subsequent amendment to the registration statement. Please ensure you address the following:

 ● Your disclosures on page 172 continue to indicate that
in connection with reporting financial statements for the quarter ended March 31, 2024 you will provide an updated analysis. Given the
financial statements have been updated through September 30, 2024, it would appear that you have performed your final analysis. In this
regard, please expand your disclosures to address any related accounting impacts and disclosure requirements.

 ● We note the additional disclosures provided in (a) and (b) on page 172. With reference to specific
terms of Milestone III, ensure how such milestones meet the requirements in (a) and (b). Ensure you provide a fulsome analysis and reference
the specific guidance in the authoritative literature that supports your accounting.

 Response :
The Co-Registrants acknowledge the Staff's comment and have revised the disclosure on pages 179 and 180 of the Amendment. The Co-Registrants further
note that following the filing of Amendment No. 10 to the Registration Statement, Milestone Event IV was revised in connection with
Amendment No. 4 to the Merger Agreement. The Co-Registrants have finalized their analysis of Milestone Event III and Milestone Event
IV and confirm that all four Milestones continue to be indexed to the Company's own stock.

 Additionally, we have included further analysis of the relied
upon accounting guidance referenced below:

 Milestones Event III and IV are Earnout Rights which meet
the definition of a derivative instrument as defined by ASC 815-10-15-59(d) . The milestones contain an underlying, notional amount
and payment provisions, they require initial net investment that is smaller than would be required for other types of contracts that would
be expected to have a similar response to changes in market factors, and they contain net settlement provisions as they relate to publicly
traded shares. Further, management referenced the Milestone Earnout Rights, Sponsor Inducement Recoupment Earnout Rights and Profusa Inducement
Recoupment Earnout Rights are considered to be indexed to the New Profusa's own stock because:

 (a) they are contingently exercisable exclusively on
the basis of the New Profusa's own share price and/or by reference to the Company's own operations (i.e. revenue targets);

 (b) their settlement amount is equal the difference between
the fair value of a fixed number of the New Profusa's equity shares and a fixed monetary amount (the amount initially invested by
the equity holders), and any adjustments to the settlement amounts do not violate the "fixed-for-fixed" principle.

 All Milestone analysis : Under ASC 480-10-55-26,
the Earnouts are not within the scope of ASC 480 as they do not embody an obligation. Thus, the Earnouts should be evaluated under ASC
815.

 The next step of analysis should be based on ASC 815-10-15-83
to determine whether the Earnouts should be accounted for as derivative instruments:

 a. Underlying, notional amount, payment provision.

 The Earnouts have an underlying amount representing the fair
value of NorthView Common Stock for Milestone I Earnout and Milestone II Earnout and the Company's revenue for Milestone III Earnout
and Milestone Event IV earnout. The notional amount for the Earnouts is the number of shares issuable upon each trigger event.

 Jack Stover NorthView Acquisition Corporation April 3, 2025 Page 5

 b. Initial net investment.

 The Earnouts require little initial net investment.
Milestone I Earnout and Milestone II Earnout is contingent upon achievement of share prices which are above the fair value of
NorthView Common Stock on the date of the Merger. Milestone III Earnout and Milestone Event IV earnout are contingent upon
achievement of certain revenue targets, while Profusa has no history of revenue. As such the fair values of the Earnouts are
significantly less than the fair value of the underlying shares. Accordingly, holding position in the Earnouts require little to no
initial investment.

 c. Net settlement.

 The net settlement criterion in ASC 815-10-15-83(c) can
be met in any one of three different ways:

 1. Contractual net settlement,

 2. Through a market mechanism, or

 3. Through delivery of a derivative or instrument that
is readily convertible to cash.

 Shares issuable to each holder of the Earnouts are publicly
traded. Therefore, the delivered asset (shares) is readily convertible to cash. As such the net settlement criterion is met.

 Based on the above, the Earnouts meet the definition of
a derivative.

 Further, for the Milestone Event III earnout and Milestone
Event IV earnout, the Company considered ASC 815-10-15-59(d) which states, "Contracts that are not exchange-traded are not subject
to the requirements of this Subtopic if the underlying on which the settlement is based on any one of the following:

 . . .

 d) Specified volumes of sales or service revenues of one of
the parties to the contract"

 Milestone Event III earnout and Milestone Event IV earnout
meet the scope exception above from derivative accounting since payments under these milestones are based on revenue amounts. Accordingly,
Milestone Event III earnout and Milestone Event IV earnout will not be accounted for as derivatives under ASC 815. However, while Milestone
III Earnout and Milestone Event IV earnout are outside the scope of the derivatives guidance of ASC 815, they will be settled in the Company's
own stock. Accordingly, they must further be analyzed under the further guidance of ASC 815-40, which is applicable to any freestanding
financial instrument that is potentially settled in an entity's own stock, regardless of whether the instrument has all the characteristics
of a derivative instrument.

 Next, the Company considered the Section: "own equity"
scope exception of PwC SPAC Guide which states, in part (emphasis added): Earnout provisions that result in financial instruments t