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November 19, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Division of Corporation Finance

Office of Energy & Transportation

Washington, D.C. 20549

Attention: Irene Barberena-Meissner, Karina Dorin,
Robert Babula and Gus Rodriguez

    Re:

    Swiftmerge Acquisition Corp.

    AleAnna Energy, LLC

    Amendment No. 3 to Registration Statement on Form S-4

    Filed November 14, 2024

    File No. 333-280699

Ladies and Gentlemen:

On behalf of Swiftmerge Acquisition
Corp. (the “SPAC”) and AleAnna Energy, LLC (the “Company”, together with the SPAC, the “Co-Registrants”),
below is the response of the SPAC and the Company to the comments of the staff of the Division of Corporation Finance (the “Staff”)
of the United States Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated November
19, 2024, regarding the Co-Registrants’ Amendment No. 3 to Registration Statement on Form S-4 filed with the Commission on November
14, 2024.

For your convenience, the Staff’s comments are set forth in bold,
followed by responses on behalf of the Co-Registrants.

Amendment No. 3 to Registration Statement on
Form S-4

Notes to Consolidated Financial Statements

Note 13-Natural Gas Producing Activities (Unaudited)

Reserve Information, page F-81

 1. We note your response to prior comment
                                            4 and the expanded reconciliation of changes in proved reserves on page F-81; however, no
                                            revision volumes are attributed to changes in sales prices. Footnote (1) explains your drilling
                                            activity during the years 2023 and 2022 as the only change in proved reserves; however, the
                                            economic limit associated with your proved reserves, as of December 31, 2023 using a volume
                                            weighted average sales price of $14.13 per Mcf, would occur sooner than if you used the year-end
                                            2022 volume-weighted average sales price of $24.55. This change in economic limit would correspond
                                            to a reduction in the forecasted volume of proved reserves; therefore, you would recognize
                                            a negative volume change due to reduced sales prices as of December 31, 2023.

The changes in the standardized
measure on page F-83 presents a negative $96.6 million decrease due to prices as of December 31, 2023, and a positive $85.2 million increase
due to prices as of December 31, 2022. Please review and revise your disclosure to present the corresponding volume changes in proved
reserves associated with the changes in the volume-weighted average sales prices as of December 31, 2023 and December 31, 2022.

In addition, please refer to FASB
ASC 932-235-50-5 for a list of significant change categories that should be presented separately in your tabular reconciliation. Note:
“Extension and Discoveries” are a separate category from “Revisions of Previous Estimates.”

As all of your reserves are proved
undeveloped, this comment also relates to the volume changes in your proved undeveloped reserves presented on page 231.

Response: The Co-Registrants acknowledge the Staff’s comment and respectfully
advise the Staff that based on the estimated operating expenses included in the reserves reports, the December 31, 2023 and 2022 natural
gas prices are above the break-even price of production such that the full volume of recoverable gas is capable of being produced prior
to reaching the economic limit. Therefore, there was no reduction in the forecasted volume of proved reserves due to price changes.

As the Co-Registrants believe the revisions below to be immaterial
clarifications and that such information would not materially alter an investor’s decision-making, the Co-Registrants advise the
Staff that they will clarify disclosures in future filings accordingly. For illustrative purposes, the Co-Registrants anticipate the revised
disclosures would be substantially similar to the following.

Page 231:

Proved Undeveloped Reserves

Our 2023 proved undeveloped reserves increased by approximately 3.9
(106ft3), or approximately 28.4%, compared to 2022. The following table provides a roll-forward of our proved undeveloped
reserves.

    Proved
 Undeveloped
 Reserves

    (106ft3)

    Balance at January 1, 2023
      13,778

    Extensions(1)
      3,911

    Discoveries(1)
      —

    Changes in sales prices(2)
      —

    Other additions(1)
      —

    Revisions of previous estimates
      —

    Balance at December 31, 2023
      17,689

 (1) Increases from extensions are solely related to the Company’s
recent Longanesi development drilling. Recent drilling activity consisted of the following: drilling of two gross Longanesi development
wells (0.67 net wells to AleAnna’s interest) during the year ended December 31, 2022, and drilling of one gross Longanesi development
well (0.335 net to AleAnna’s interest) during the year ended December 31, 2023. The 3,911 106ft3 of reserves
added during the year ended December 31, 2023 relate to the drilling of one gross Longanesi development well (0.335 net to AleAnna’s
interest) during the year ended December 31, 2023.We had no other exploratory or development drilling during the years ended December
31, 2023 or 2022. The Company also had no other additions during the year ended December 31, 2023.

 (2) AleAnna’s existing reserves were considered economic and were
expected to be recovered at the volume-weighted average price attributable to the estimated proved reserves of $14.13 and $24.55 per thousand
cubic feet of gas for the year ended December 31, 2023, and 2022. Per the December 31, 2023 and 2022 reserves reports, the full volume
of total proved undeveloped reserves is produced within the economic limit of the reservoir despite the significant change in prices year
over year. Based on the estimated operating expenses included in the reserves reports, the December 31, 2023 and 2022 natural gas prices
are above the break-even price of production such that the full volume of recoverable gas is capable of being produced prior to reaching
the economic limit. As a result, there were no revisions to volumes in either year as a result of changes in sales prices during the years
ended December 31, 2023 and 2022.

    2

Page F-81:

Reserve Information

Proved developed reserves represent
only those reserves expected to be recovered from existing wells and support equipment. Proved undeveloped reserves represent proved reserves
expected to be recovered from new wells after substantial development costs are incurred.

The net reserve information
disclosed herein encompasses only the Company’s proved undeveloped Gradizza, Longanesi, and Trava discoveries. Other probable and
possible reserves related to Gradizza, Longanesi, and Trava have been excluded. Other prospective resources related to AleAnna’s
additional exploration prospects beyond Gradizza, Longanesi, and Trava have also been excluded. The following table summarizes estimated
net natural gas reserves in millions of cubic feet.

    December 31,

    2023
    2024

    (106ft3)

    Natural gas

    Proved developed and undeveloped reserves:

    Balance at January 1
      13,778
      11,735

    Extensions(1)
      3,911
      2,043

    Discoveries(1)
      —
      —

    Changes in sales prices(2)
      —
      —

    Other additions(1)
      —
      —

    Revisions of previous estimates
      —
      —

    Balance at December 31
      17,689
      13,778

    Proved developed reserves:

    Balance at January 1
      —
      —

    Balance at December 31
      —
      —

    Proved undeveloped reserves:

    Balance at January 1
      13,778
      11,735

    Extensions(1)
      3,911
      2,043

    Discoveries(1)
      —
      —

    Changes in sales prices(2)
      —
      —

    Other additions(1)
      —
      —

    Revisions of previous estimates
      —
      —

    Balance at December 31
      17,689
      13,778

 (1) Increases from extensions are solely related to the Company’s
recent Longanesi development drilling. Recent drilling activity consisted of the following: drilling of two gross Longanesi development
wells (0.67 net wells to AleAnna’s interest) during the year ended December 31, 2022, and drilling of one gross Longanesi development
well (0.335 net to AleAnna’s interest) during the year ended December 31, 2023. The 2,043 106ft3 of reserves
added during the year ended December 31, 2022 relate to the drilling of two gross Longanesi development wells (0.67 net wells to AleAnna’s
interest) during the year ended December 31, 2022. The 3,911 106ft3 of reserves added during the year ended December
31, 2023 relate to the drilling of one gross Longanesi development well (0.335 net to AleAnna’s interest) during the year ended
December 31, 2023. There were no other positive or negative revisions to reserves other than the reserves added as a result of drilling.
We had no other exploratory or development drilling during the years ended December 31, 2023 or 2022. The Company also had no other additions
during the years ended December 31, 2023 or 2022.

 (2) AleAnna’s existing reserves were considered economic and were
expected to be recovered at the volume-weighted average price attributable to the estimated proved reserves of $14.13 and $24.55 per thousand
cubic feet of gas for the year ended December 31, 2023, and 2022. Per the December 31, 2023 and 2022 reserves reports, the full volume
of total proved undeveloped reserves is produced within the economic limit of the reservoir despite the significant change in prices year
over year. Based on the estimated operating expenses included in the reserves reports, the December 31, 2023 and 2022 natural gas prices
are above the break-even price of production such that the full volume of recoverable gas is capable of being produced prior to reaching
the economic limit. As a result, there were no revisions to volumes in either year as a result of changes in sales prices during the years
ended December 31, 2023 and 2022.

    3

Page F-83:

NOTE
13 — NATURAL GAS PRODUCING ACTIVITIES (UNAUDITED)

The following table summarizes
the aggregate change in the standardized measure of discounted future net cash flows for individually significant sources of change (in
thousands).

    December 31,

    2023
    2022

    Beginning standardized measure of discounted future net cash flows
    $ 90,474
    $ 4,984

    Net change in sales prices related to future production(1)
      (96,635 )
      85,224

    Net change due to extensions(2)
      51,044
      11,050

    Previously estimated development costs incurred during the period
      3,281
      7,943

    Net change in income taxes
      21,579
      (19,164 )

    Accretion of discount
      181
      437

    Revisions of previous estimates(1)
    $ —
    $ —

    Aggregate change in the standardized measure of discounted future net cash flows(3)
      (20,550 )
      85,490

    Ending standardized measure of discounted future net cash flows
    $ 69,924
    $ 90,474

 (1) Gas prices are based on a reference price. Gross gas price is calculated
as the unweighted arithmetic average of the first day-of-the-month price for each month within a 12-month period prior to the end of the
reporting period. The volume-weighted average price attributable to the estimated proved reserves was $14.13 and $24.55 per thousand cubic
feet of gas for the year ended December 31, 2023, and 2022, respectively. AleAnna’s existing reserves were considered economic and
were expected to be recovered at the volume-weighted average price attributable to the estimated proved reserves of $14.13 and $24.55
per thousand cubic feet of gas for the year ended December 31, 2023, and 2022. Per the December 31, 2023 and 2022 reserves reports, the
full volume of total proved undeveloped reserves is produced within the economic limit of the reservoir despite the significant change
in prices year over year. Based on the estimated operating expenses included in the reserves reports, the December 31, 2023 and 2022 natural
gas prices are above the break-even price of production such that the full volume of recoverable gas is capable of being produced prior
to reaching the economic limit. As a result, there were no revisions to volumes in either year as a result of changes in sales prices
during the years ended December 31, 2023 and 2022.

 (2) Increases from extensions are solely related to the Company’s
recent Longanesi development drilling. Recent drilling activity consisted of the following: drilling of two gross Longanesi development
wells (0.67 net wells to AleAnna’s interest) during the year ended December 31, 2022, and drilling of one gross Longanesi development
well (0.335 net to AleAnna’s interest) during the year ended December 31, 2023. The 2,043 106ft3 of reserves
added during the year ended December 31, 2022 relate to the drilling of two gross Longanesi development wells (0.67 net wells to AleAnna’s
interest) during the year ended December 31, 2022. The 3,911 106ft3 of reserves added during the year ended December
31, 2023 relate to the drilling of one gross Longanesi development well (0.335 net to AleAnna’s interest) during the year ended
December 31, 2023. There were no other positive or negative revisions to reserves other than the reserves added as a result of drilling.
We had no other exploratory or development drilling during the years ended December 31, 2023 or 2022. AleAnna’s existing reserves
were considered economic and were expected to be recovered at the volume-weighted average price attributable to the estimated proved
reserves of $14.13 and $24.55 per thousand cubic feet of gas for the year ended December 31, 2023, and 2022. As a result, there were
no revisions to volumes in either year as a result of changes in sales prices during the years ended December 31, 2023 and 2022. The
Company also had no other additions during the years ended December 31, 2023 or 2022.

 (3) From December 31, 2021 to December 31, 2022, the standardized
measure of discounted future net cash flows increased due to both the increase in reserves from extensions as well as an increase in
the volume-weighted average price attributable to the estimated proved reserves. From December 31, 2022 to December 31, 2023, the standardized
measure of discounted future net cash flows decreases as a result of lower prices as noted immediately above in footnote 1. The decrease
in price more than offset the increase in reserves from extensions during the year ended December 31, 2023, resulting in a net decrease
to the standardized measure of discounted future cash flows from December 31, 2022 to December 31, 2023.

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If you have any questions
or require any additional information in connection with the filing, please do not hesitate to contact the undersigned at 954-768-8209.

    Very truly yours,

    /s/ Grant J. Levine

    Grant J. Levine

    Greenberg Traurig, LLP

    cc:
    Tristan Yopp, Chief Financial Officer of AleAnna Energy, LLC

    Jennifer T. Wisinski, Esq., Haynes and Boone, LLP

    Stephen W. Grant Jr., Esq., Haynes and Boone, LLP

    John Bremner, Chief Executive Officer of Swiftmerge Acquisition Corp.

    Mark Selinger, Esq., Greenberg Traurig, LLP

    Adam Namoury, Esq., Greenberg Traurig, LLP

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