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                                            9 Raffles Place

                                            #42-02 Republic Plaza

                                            Singapore 048619

                                            Tel: +65.6536.1161 Fax: +65.6536.1171

                                            www.lw.com

                                            UEN No. T09LL1649F

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  August 13, 2024
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VIA EDGAR

Division of Corporation Finance

Office of Real Estate & Construction

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ron Alper and Pam Long

 Re: Black Spade Acquisition II Co

Amendment No. 2 to Registration
Statement on Form S-1

Filed August 12, 2024

File No. 333-280385

Dear Sir or Madam:

Our
client, Black Spade Acquisition II Co, a blank check company incorporated under the laws of the Cayman Islands as an exempted company
with limited liability (the “Company”), is hereby filing Amendment No. 3 to the above-referenced Registration
Statement on Form S-1 (“Amendment No. 3”) concurrently with this letter solely to correct certain portions
of Amendment No. 2 to the above-referenced Registration Statement that relate to the Company’s response to Comment No. 2
of your comment letter dated August 9, 2024 (the “Comment Letter”).

Comment
No. 2 of the Comment Letter is repeated below in italic and is followed by the Company’s response. We have included
page references to Amendment No. 3 where the response refers to the revised disclosure therein. Capitalized terms used but
not otherwise defined herein have the meanings set forth in Amendment No. 3.

Amendment No. 1 to Registration Statement
on Form S-1 filed July 24, 2024

If we seek shareholder approval of our initial
business combination . . ., page 46

 2. We note your disclosure added in response
                                            to comment 9. However, existing disclosure continues to state that the purpose of any purchases
                                            of shares “could be to vote such shares in favor of the business combination . . .
                                            “ Please revise to remove the implication that the sponsor, officers or directors could
                                            purchase shares during the restricted period and vote them in favor of the business combination.

Response:
In response to the Staff’s comment, the Company has revised the disclosure on pages 30, 46 and 139 of the Amendment
No. 3.

If
you have any questions regarding the Registration Statement, please contact Sharon Lau (sharon.lau@lw.com or +65 6437 5464) or
Stacey Wong (stacey.wong@lw.com or +65 6437 5450) of Latham & Watkins LLP.

    August 13, 2024

    Page 2

Thank you for your time
and attention.

    Very truly yours,

    /s/ Stacey Wong

    Stacey Wong

    of LATHAM &WATKINS LLP

Enclosure

 cc: (via email)

Dennis Tam, Executive Chairman
and Co-Chief Executive Officer, Black Spade Acquisition II Co

Kester Ng, Co-Chief Executive Officer
and Chief Financial Officer, Black Spade Acquisition II Co

Richard Taylor, Co-Chief Executive
Officer and Chief Operating Officer, Black Spade Acquisition II Co

Sharon Lau, Partner, Latham &
Watkins LLP

Mitchell S. Nussbaum, Partner,
Loeb & Loeb LLP

David
J. Levine, Partner, Loeb & Loeb LLP