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    Linklaters LLP

    1290 Avenue of the Americas

 New York, NY 10104

Telephone
    (+1) 212 903 9000

    Facsimile (+1) 212 903 9100

November 21, 2022

Via EDGAR Submission

Securities and Exchange Commission

Division of Corporate
Finance

Office of Manufacturing

 100 F Street, N.E.

Washington,
D.C. 20549

    Attention:
    Kevin Stertzel

    Melissa Gilmore

    Bradley Ecker

    Erin Purnell

    Re:
    Moolec Science SA

    Registration Statement on Form F-4

    Filed on October 17, 2022

    File No. 333-267912

Ladies and Gentlemen:

Moolec Science
SA (the “Company”) previously submitted the registration statement on Form F-4 to the Securities and Exchange Commission
(the “SEC”) on October 17, 2022 (the “Registration Statement”).

On behalf
of the Company, we are writing to respond to the comments set forth in the comment letter (the “Comment Letter”) from
the staff of the SEC (the “Staff”) dated October 28, 2022. The Company’s responses below correspond to the captions
and numbers of those comments (which are reproduced below in bold). Simultaneously with the submission of this letter, the Company is
filing amendment No. 1 to the Registration Statement (“Amendment No. 1 to the Registration Statement”).

Form F-4 filed October 17, 2022

Unaudited Pro Form Combined Financial Information, page
82

 1. We note your agreements provide that “EarlyBird” shall receive cash fees
at the point the transactions are consummated and share fees within roughly 6 months of the anniversary of the closing. It appears you
should include pro forma adjustments for these agreements in your pro forma financial information, or otherwise please explain to us why
you believe these amounts should not be reflected in your presentation.

In response to the Staff’s comment, the Company has revised its
disclosure on pages 88 and 89 of Amendment No. 1 to the Registration Statement. The Company respectfully informs the Staff that the variable
number of shares to be issued to EarlyBird will have a neutral effect because the Sponsor of the SPAC has agreed to forfeit the same number
of shares of the Company.

MATERIAL U.S. FEDERAL INCOME TAX CONSIDERATIONS, page 130

 2. We note that you have filed a short-form tax opinion as Exhibit 8.1. Please therefore
revise the tax disclosure in the prospectus to state clearly that the disclosure in the tax consequences section of the prospectus is
the opinion of the named counsel. Please refer to Section III.B.2. of Staff Legal Bulletin No. 19 for more information. In addition, please
file a final, executed, version of Exhibit 8.1 in a pre-effective amendment to the registration statement.

In response to the Staff’s comment, the Company has revised its
disclosure on pages 130 and 132-134 of Amendment No. 1 to the Registration Statement. A final, executed version of the legal opinion is
also included as Exhibit 8.1 to Amendment No. 1 to the Registration Statement.

General

 3. We note that the SPAC Sponsor and affiliates of Moolec Science have announced their
intention to potentially purchase SPAC securities from redeeming stockholders to ensure the minimum cash amount is met. Please provide
your analysis on how such purchases comply with Rule 14e-5.

The Company respectfully acknowledges
the Staff’s comments and makes reference to Compliance and Disclosure Interpretation (“C&DI”) Question 166.01 related
to the list of parameters under which the Staff would permit any such applicable purchases of SPAC securities by the SPAC sponsor or its
affiliates outside of the redemption offer.

The Company agrees and confirms that any purchase of SPAC securities
will comply with the conditions indicated in C&DI Question 166.01. In response to the Staff’s comments, the Company has also
revised its disclosure on pages 16, 17, 74, 125, 171 and 218 of Amendment No. 1 to the Registration Statement to clarify that any Public
Shares purchased by the SPAC Sponsor or affiliates of Moolec Science will (i) be purchased at a price no higher than the price offered
through the SPAC redemption process, (ii) not be voted in favor of the business combination transaction and (iii) not have redemption
rights, or such rights would be waived. The Company also respectfully informs the Staff that the SPAC intends to file in a Form 8-K the
requisite information outlined in C&DI Question 166.01.

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We hope that the above has been responsive
to the Staff’s comments. Should you have any questions relating to the foregoing, please feel free to contact the undersigned at
(212) 903-9306 or matthew.poulter@linklaters.com.

    Yours faithfully,

    /s/ Matthew S. Poulter

    Matthew S. Poulter, Esq.

    cc:
    Leib Orlanski, K&L Gates LLP

Leib.Orlanski@klgates.com

(310) 552-5044

    Matt Ogurick, K&L Gates LLP

Matthew.Ogurick@klgates.com

(917) 292-3333

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