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November 19, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Frank Knapp

    Jennifer Monick

    Ronald (Ron) E. Alper

    Brigitte Lippmann

    Re:
    Translational Development Acquisition Corp.

    Registration Statement on Form S-1

    Filed October 22, 2024

    File No. 333-282763

Ladies and Gentlemen:

On behalf of our client,
Translational Development Acquisition Corp. (the “Company,” “we,” “our” or “us”),
we are responding to the comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
in your letter dated November 5, 2024 (the “Comment Letter”), with respect to the above-captioned Registration
Statement on Form S-1 (the “Registration Statement”).

For your convenience, each
of the Staff’s comments contained in the Comment Letter is duplicated below in bold and is followed by the Company’s response.

All references in this letter
to page numbers and captions (other than those in the Staff’s comments) correspond to the page numbers in the Registration
Statement on Form S-1 publicly filed with the Commission on November 20, 2024 (the “Registration Statement”),
unless otherwise noted. Defined terms used but not otherwise defined herein have the meanings ascribed to such terms in the Registration
Statement.

November 19, 2024

Page 2

Registration Statement on Form S-1 filed October 22,
2024

Cover Page

1. We
                                            note your response to prior comment 2. Please also describe the private placement warrants
                                            issuance to your sponsor and the price paid for the private placement warrants where you
                                            discuss material dilution to your public shareholders.

Response:
We have revised the prospectus cover page of the Registration Statement.

General

 2. We
                                            note your response to prior comment 11. We are considering your response and may have further
                                            comment.

Response:
We have revised the disclosure in the Registration Statement on the cover page and pages 15, 150 and 164.

3. We
                                            note your disclosure regarding the assignment and novation agreement pursuant to which Stone
                                            Capital Partners LLC's rights, obligations and liabilities under the previous subscription
                                            agreement were transferred to and assumed by TDAC Partners LLC and TDAC Partners LLC became
                                            your current sponsor. We also note that Michael B. Hoffman is the managing member and owns
                                            100% of the economic interests in both entities. Please disclose the purpose of the assignment
                                            and novation agreement.

Response:
We have revised the disclosure in the Registration Statement on pages 1, 21, 24, 69, 163 and 168.

* * *

November 19, 2024

Page 3

Thank you for your attention to this response. If you have any questions
related to this letter, please contact the undersigned at (212) 503-9812.

    Very truly yours,

    /s/ William N. Haddad

    William N. Haddad

    Venable LLP

    cc:
    Michael B. Hoffman, Translational Development Acquisition Corp.

    Avanindra C. Das, Translational Development Acquisition Corp.

    Arif Soto, Venable LLP

    Mitchell S. Nussbaum, Loeb & Loeb LLP

    David J. Levine, Loeb & Loeb LLP