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 345
 Park Avenue
 New
 York, NY 10154-1895
 Direct
Main
Fax
 212.407.4000

 212.407.4000
 212.407.4990

 Via
Edgar

 March
18, 2025

 Erin
Donahue

 Asia
Timmons-Pierce

 Division
of Corporation Finance

 Office
of Manufacturing

 U.S.
Securities and Exchange Commission

 100
F Street, N.E.

 Washington,
D.C. 20549

 Re:
 Iron Horse Acquisitions
 Corp.

 Amendment
 No. 1 to Registration Statement on Form S-4
 Filed
 January 28, 2025
 File
 No. 333-283933

 Dear
Ms. Donahue and Ms. Timmons-Pierce:

 On
behalf of our client, Iron Horse Acquisitions Corp., a Delaware corporation (the " Company "), we submit to the
staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " SEC ") this
letter setting forth the Company's response to the comments contained in the Staff's letter dated February 12, 2025 (the
 " Comment Letter " ) regarding the Company's Amendment No. 1 to Registration Statement on Form S-4 (the
" Registration Statement ").

 The
Company has filed via EDGAR an Amendment No. 2 to the Registration Statement on Form S-4 (the " Amended Registration Statement "),
which reflects the Company's responses to the Comment Letter and certain updated information. Please note that our responses below,
insofar as relevant information relates to Zhong Guo Liang Tou Group Ltd (" CFI ") or matters arising from CFI's
participation in the preparation of the Registration Statement and the Amended Registration Statement, are based on our discussions with
and information received from CFI or its counsel, iTKG Law LLC, who have similarly participated in the preparation and review of this
response letter.

 For
ease of reference, each comment contained in the Comment Letter is printed below and is followed by the Company's response. All
page references in the responses set forth below refer to the page numbers in the Amendment Registration Statement. All capitalized terms
used but not defined in this response letter have the meanings ascribed to such terms in the Amended Registration Statement.

 Amendment
No. 1 to Registration Statement Form F-4/A filed January 28, 2025

 What
vote is required to approve the Proposals?, page xiv

 1.
 We note
 your amended disclosure and your response to prior comment 5. State whether or not the de-SPAC transaction is structured so that
 approval of at least a majority of unaffiliated security holders of Iron Horse is required. Please refer to Item 1606(c) of Regulation
 S-K. Add any appropriate risk factors.

 Response :
The Company acknowledges the Staff's comment and respectfully advises the Staff that it has revised its disclosure on page (v)
and elsewhere in the Amended Registration Statement to disclose that no separate vote of a majority of the unaffiliated stockholders
is received.

 Summary,
page 1

 2.
 We note
 your response to prior comment 12 and your amended disclosure, and reissue in part. We note your disclosure on page 1 that states
 redemption rights apply in the event of an approval of an amendment to the company's amended and restated certificate of incorporation
 to extend the time to complete a business combination beyond 18 months. Please revise to state whether shareholders may redeem their
 shares in connection with the two allowable three months extensions.

 Response :
The Company acknowledges the Staff's comment and respectfully advises the Staff that it has revised its disclosure on page and
elsewhere to disclose that there are no redemption rights in connection with the two allowable extensions.

 The
approval or relevant PRC regulatory authorities and compliance procedures.. , page 49

 3.
 We note
 your risk factor disclosure on page 50 that it is the opinion of Jingsh & H Y Leung that your business operations do not currently
 involve data processing. Please file this opinion as an exhibit.

 Response :
The Company acknowledges the Staff's comment and respectfully advises the Staff that it has filed the opinion of Guangdong Xinyu
Law Firm as an exhibit.

 Material
U.S. Federal Income Tax Consequences, page 100

 4.
 We are
 still considering your response to prior comment 24 and we may have further comments.

 Response :
The Company acknowledges the Staff's comment.

 Iron
Horse's Business, page 108

 5.
 We note
 your disclosure on page 111 that "None of our Sponsor, directors and officers have any SPAC experience prior to Iron Horse."
 Please revise this disclosure to include any SPAC experience post Iron Horse. For instance, we note Mr. Bengochea and Mr. Caragol
 are both executive officers of Iron Horse Acquisition II, which recently filed its IPO.

 Response :
The Company acknowledges the Staff's comment and respectfully advises the Staff that it has revised its disclosure on page 110.

 Compensation
of Directors and Executive Officers, page 203

 6.
 Please
 update to include compensation for fiscal year end December 31, 2024.

 Response :
The Company acknowledges the Staff's comment and respectfully advises the Staff that it has revised its disclosure on page 203.

 Notes
to Unaudited Consolidated Financial Statements

 Revenue
Recognition - Wholesale distribution segment, page F-61

 7.
 We note
 in your response to comment 39, your reference to TRG 46, and the revised disclosure on page F-61. Please clarify for us whether
 you allocate part of the transaction price to the customer's right to minimum purchase volumes required by the distributor
 agreements. Otherwise, explain to us what would give rise to any remaining revenue associated with a minimum purchase volume to which
 you refer. Given your disclosure that you determined that minimum purchase volumes required by the distributor agreements, if any,
 do not provide a distributor a material right that gives rise to a separate performance obligation, explain to us how you considered
 ASC 606-10-55-43 in your accounting. Please explain to us in detail how you applied the guidance in ASC 606-10-55-41 to ASC 606-10-55-49
 to your accounting for your customers rights to minimum purchase volumes required by the distributor agreements.

 Response :
The Company acknowledges the Staff's comment and respectfully advises the Staff that it does not allocate part of the transaction
price to the customer's right to minimum purchase volumes required by the distributor agreements.

 2

 A
customer option should be accounted for as a separate performance obligation only if it provides a material right to the customer that
the customer would not receive without entering into the distributor agreement. ASC 606-10-55-41 through 55-45 explain the accounting
for customer options for additional goods or services as follows:

 ASC
606-10-55-41 Customer options to acquire additional goods or services for free or at a discount come in many forms, including
sales incentives, customer award credits (or points), contract renewal options, or other discounts on future goods or services.

 ASC
606-10-55-42 If, in a contract, an entity grants a customer the option to acquire additional goods or services, that
option gives rise to a performance obligation in the contract only if the option provides a material right to the customer that it would
not receive without entering into that contract (for example, a discount that is incremental to the range of discounts typically given
for those goods or services to that class of customer in that geographical area or market). If the option provides a material right to
the customer, the customer in effect pays the entity in advance for future goods or services, and the entity recognizes revenue when
those future goods or services are transferred or when the option expires.

 ASC
606-10-55-43 If a customer has the option to acquire an additional good or service at a price that would reflect the
standalone selling price for that good or service, that option does not provide the customer with a material right even if the option
can be exercised only by entering into a previous contract. In those cases, the entity has made a marketing offer that it should account
for in accordance with the guidance in this Topic only when the customer exercises the option to purchase the additional goods or services.

 ASC
606-10-55-44 Paragraph 606-10-32-29 requires an entity to allocate the transaction price to performance
obligations on a relative standalone selling price basis. If the standalone selling price for a customer's option to acquire additional
goods or services is not directly observable, an entity should estimate it. That estimate should reflect the discount that the customer
would obtain when exercising the option, adjusted for both of the following:

 a.
Any discount that the customer could receive without exercising the option

 b.
The likelihood that the option will be exercised.

 ASC
606-10-55-45 If a customer has a material right to acquire future goods or services and those goods or services are similar
to the original goods or services in the contract and are provided in accordance with the terms of the original contract, then an entity
may, as a practical alternative to estimating the standalone selling price of the option, allocate the transaction price to the optional
goods or services by reference to the goods or services expected to be provided and the corresponding expected consideration. Typically,
those types of options are for contract renewals.

 Based
on the above guidance, the Company evaluated whether the customer's option to acquire an additional good under the distributor
agreement provides the customer with a material right, noting the following:

 ● the
 contractual purchase volume minimal included in a distributor agreement with a customer represents
 a promise to transfer specified goods, not a stand-ready obligation, as the terms of the
 distributor agreement require customers to submit purchase orders with a specific number
 of distinct good(s) at a later date in order to create an obligation for the Company to perform
 (and the customer to pay). Accordingly, each customer purchase order creates a performance
 obligation for the Company, not the distributor agreement itself.

 ● the
 selling price of the goods stated in the distributor agreement is consistent across all distributors.
 The Company only sells its products to customers with whom a distributor agreement has been
 entered into. As such, the price of goods in the distributor agreements reflects the standalone
 selling price of the goods.

 3

 ● the
 customer's option to acquire additional goods under a distributor agreement reflects
 the standalone selling price for those goods.

 ● in
 instances where there is a shortfall to the contractual purchase volume minimum at the end
 of the distributor agreement's term, the distributor agreement's term require
 the customer to pay for the amount of the shortfall at the standalone selling price setforth
 in the distributor agreement. If the customer does meet the contractual purchase volume minimum
 during the term of the distributor agreement, the standalone selling price of the good continues
 to be in effect for future purchases. There is no discount to the standalone selling price
 on additional purchases of goods based on achieving or missing the contractual purchase volume
 minimum.

 As
a result, the customer's right to a contractual purchase volume minimum provided in the distributor agreement is not considered
a material right to the customer and there is accordingly no additional, separate performance obligation to account for. A customer's
right to a contractual purchase volume minimum would be accounted for when it is exercised by a customer.

 A
customer's purchase shortfall to a contractual purchase volume minimum was determined to represent unexercised rights, the accounting
of which are explained by the ASC 606-10-55-46 through 55-49 as follows:

 ASC
606-10-55-46 In accordance with paragraph 606-10-45-2, upon receipt of a prepayment from a customer, an entity should
recognize a contract liability in the amount of the prepayment for its performance obligation to transfer, or to
stand ready to transfer, goods or services in the future. An entity should derecognize that contract liability (and recognize revenue)
when it transfers those goods or services and, therefore, satisfies its performance obligation.

 ASC
606-10-55-47 A customer's nonrefundable prepayment to an entity gives the customer a right to receive a good or service in
the future (and obliges the entity to stand ready to transfer a good or service). However, customers may not exercise all of their contractual
rights. Those unexercised rights are often referred to as breakage.

 ASC
606-10-55-48 If an entity expects to be entitled to a breakage amount in a contract liability, the entity should recognize
the expected breakage amount as revenue in proportion to the pattern of rights exercised by the customer. If an entity does not expect
to be entitled to a breakage amount, the entity should recognize the expected breakage amount as revenue when the likelihood of the customer
exercising its remaining rights becomes remote. To determine whether an entity expects to be entitled to a breakage amount, the entity
should consider the guidance in paragraphs 606-10-32-11 through 32-13 on constraining estimates of variable consideration.

 ASC
606-10-55-49 An entity should recognize a liability (and not revenue) for any consideration received that is attributable
to a customer's unexercised rights for which the entity is required to remit to another party, for example, a government entity in accordance
with applicable unclaimed property laws.

 Based
on the above guidance, the Company evaluated whether it should record revenue related to a customer's unexercised rights noting
the following:

 ● the
 Company does not receive prepayments from its customers, rather the Company is paid for the
 performance obligations only after the performance obligations are satisfied.

 ● No
 distributor agreements reached the end of the original term nor were any distributor agreements
 terminated early as of September 30, 2024

 ● the
 standalone selling price remains fixed throughout the duration of the distribution agreement,
 regardless of whether the contractual purchase volume minimum is met or not.

 ● in
 the case of a customer's shortfall to a contractual purchase volume requirement at
 the end of the term of a distributor agreement, a customer would not have exercised its obligation
 ("option") to purchase the remaining goods under the distribution agreement and
 no future deliveries would be expected under the distribution agreement.

 4

 ● the
 Company is in its first year of operations and therefore lacks history with its customers
 to estimate the probability of a customer's shortfall to a contractual purchase volume
 minimum or the probability that a customer would pay the amount of the shortfall

 As
a result, the Company should record revenue related to a customer's unexercised rights in proportion to the pattern of rights exercised
by the customer, assuming an appropriate estimate of the amount of consideration the Company would receive could be made. ASC 606-10-55-48 refers
to the guidance in ASC 606-10-32-11 through 32-13 on constraining estimates of variable consideration in cases where there
is significant uncertainty to the amounts that a company will ultimately receive. Given the significant uncertainty around the Company's
ability to estimate the occurrence and amount of a purchase shortfall to a contractual purchase volume minimum, as well as the probability
of a customer payment for the purchase shortfall to a contractual purchase volume minimum, no revenue was recognized by the Company during
the nine months ended September 30, 2024 since it was not deemed probable that a significant reversal in revenue recognized would not
occur when the uncertainty was resolved.

 At
the end of each reporting period, the Company will up