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CORRESP
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March 10, 2023

Via EDGAR

Division of Corporation Finance

Office of Real Estate & Construction

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: William Demarest

 Re: Trailblazer Merger Corporation
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    Amendment No. 2 to Registration Statement on
                                            Form S-1/A

    Filed January 31, 2023

    File No. 333-265914

Dear Mr. Demarest:

Trailblazer Merger Corporation
I, a Delaware corporation (the “Company”), hereby submits to the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) this letter setting forth the Company’s response to the comments contained in
the Staff’s letter dated February 15, 2023 (the “Comment Letter”) regarding the Company’s Draft Registration
Statement on Form S-1, submitted January 31, 2023 (the “Draft Registration Statement”). In response to the Comment Letter
and to update certain information in the Draft Registration Statement, the Company is contemporaneously filing herewith a revised Draft
Registration Statement (the “Amended Draft Registration Statement”) with the Commission.

For ease of reference, each
comment contained in the Comment Letter is reproduced below and is followed by the Company’s response. All page references in the
responses set forth below refer to the page numbers in Amended Draft Registration Statement.

Amendment No. 2 to Registration Statement on Form S-1/A filed January
31, 2023

Risk Factors

The Excise Tax included in the Inflation Reduction Act of 2022
may decrease the value of our securities... , page 54

1. We note your disclosure as to the
                                            potential effects of the stock buyback excise tax enacted as part of the Inflation Reduction
                                            Act in August 2022. If applicable, include in your disclosure that the excise tax could reduce
                                            the trust account funds available to pay redemptions or that are available to the combined
                                            company following a de-SPAC.

Describe the risks of the excise tax applying to
redemptions in connection with:

 · liquidations
                                            that are not implemented to fall within the meaning of “complete liquidation”
                                            in Section 331 of the Internal Revenue Code,

 · extensions,
                                            depending on the timing of the extension relative to when the SPAC completes a de-SPAC or
                                            liquidates, and

 · de-SPACs,
                                            depending on the structure of the de-SPAC transaction.

Also describe, if applicable, the risk
that if existing SPAC investors elect to redeem their shares such that their redemptions would subject the SPAC to the stock buyback
excise tax, the remaining shareholders that did not elect to redeem may economically bear the impact of the excise tax.

RESPONSE: Upon consideration
of the Staff’s comment and the recently issued interim guidance from the Internal Revenue Service and Treasury in Notice 2023-2,
page 54 of Amendment No. 3 has been revised to delete the Excise Tax risk factor on page 54. The Company intends to rely solely on the
Excise Tax risk factor set forth on pages 67.

2. Please revise
                                            to reconcile your disclosure regarding the risk that non-redeeming stockholders may bear
                                            the economic impact of the excise tax included in the Inflation Reduction Act of 2022. In
                                            this regard, we note that on page 54 you state that “the application of the Excise
                                            Tax in the event of a liquidation is uncertain, and the proceeds held in the trust account
                                            could be subject to the Excise Tax, in which case the per-share amount that would otherwise
                                            be received by our stockholders in connection with our liquidation may be reduced.”
                                            However, on page 68 you state that “the Excise Tax should not apply in the event of
                                            our liquidation.”

RESPONSE: Upon consideration
of the Staff’s comment, page 54 of Amendment No. 3 has been revised to delete the Excise Tax risk factor on page 54.

Exhibits

3. Please file as an exhibit the advisory agreement you entered
                                            into with one of your underwriters in September 2022.

RESPONSE: The advisory agreement
and the amendment thereto, dated March 9, 2023, have been filed as Exhibit 10.12 and Exhibit 10.13, respectively, to Amendment No.
3.

General

4. Please revise
                                            to reconcile your disclosure regarding the exclusive forum provision of your rights agreement.
                                            In this regard, we note that on pages 63 and 132 you state that the provision applies to
                                            claims under the Securities Act. However, section 7.3 of your rights agreement states that
                                            the provision “will not apply to...any complaint asserting a cause of action arising
                                            under the Securities Act against the Company or any of the Company’s directors, officers,
                                            other employees or agents.”

RESPONSE: The Company has revised page 63 and page
131 in response to the Staff’s comments.

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5. Please revise
                                            to reconcile your disclosure regarding the exclusive forum provision of your amended and
                                            restated certificate of incorporation. In this regard, we note that on pages 67 and 156 you
                                            state that your amended and restated certificate of incorporation provides that the federal
                                            district courts of the United States of America shall be the exclusive forum for any complaint
                                            arising under the Securities Act of 1933. However, your amended and restated certificate
                                            of incorporation does not appear to include such a provision. Further, we note that Securities
                                            Act of 1933 claims are excepted from the Court of Chancery of the State of Delaware exclusive
                                            forum provision found in article ten of your amended and restated certificate of incorporation.

RESPONSE: The Company has revised page 66 and
page 135 in response to the Staff’s comments.

Should you have any questions
relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact our legal counsel Alexandria Kane
at (212) 407-4017 or akane@loeb.com. Thank you for your time and attention to this filing.

    Sincerely,

    /s/ Arie Rabinowitz

    Arie Rabinowitz

    Chief Executive Officer

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