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CORRESP
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VIA EDGAR

August 21, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, NE

Washington, D.C. 20549

Attention: Stacie Gorman

 Re: Bleichroeder
                                            Acquisition Corp. I

    Registration Statement on Form S-1

    Filed July 12, 2024

    File No. 333-280777

Dear Ms. Gorman:

Bleichroeder Acquisition Corp.
I (the “Company”) hereby transmits its response to the comment letter received from the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) on August 9, 2024 relating to the Registration Statement
on Form S-1, filed by the Company with the Commission on July 12, 2024.

For the Staff’s convenience,
we have repeated below the Staff’s comment in bold and have followed each comment with the Company’s response. Disclosure
changes made in response to the Staff’s comments have been made in the Amendment to the Registration Statement on Form S-1 (the
“Registration Statement”), which is being submitted to the Commission contemporaneously with the submission of this
letter.

Registration Statement on Form S-1

Cover Page

 1. We note your disclosure in the fifth paragraph of the cover
                                            page. Please ensure that the amount of compensation received by and securities issued to,
                                            or to be received by or issued to each of the sponsor, its affiliates and promoters is clearly
                                            stated on the cover page. The disclosure should also include the price paid or to be paid
                                            for any securities, as well as the cross reference to the location of related disclosure
                                            elsewhere in the prospectus, including that provided in response to Item 1602(b)(6) and Item
                                            1603(a)(6) of Regulation S-K. Please see Item 1602(a)(3) of Regulation S-K.

We have revised the indicated disclosure in response to
the Staff’s comment.

 2. Where you discuss dilution to public shareholders resulting
                                            from the issuance of founder shares at a nominal price, please revise to also state whether
                                            the anti-dilution adjustment to the founder shares in connection with your initial business
                                            combination may result in a material dilution of the purchasers’ equity interests.

We have revised the indicated disclosure in response to
the Staff’s comment.

 3. We note your disclosure in the sixth and fifteenth paragraphs
                                            of the cover page regarding some of the potential conflicts of interest that your sponsor,
                                            co-founders and members of management may have. Please revise to state clearly that there
                                            may be actual or potential material conflicts of interest between the sponsor, its affiliates,
                                            or promoters on one hand, and purchasers in the offering on the other. Also ensure that your
                                            cross reference includes the location of related disclosure elsewhere in the prospectus,
                                            including that provided in response to Item 1602(b)(7) and Item 1603(b) of Regulation S-K.
                                            Please refer to Item 1602(a)(5) of Regulation S-K.

We have revised the indicated disclosure in response to
the Staff’s comment.

Initial Business Combination, page 7

 4. Please disclose whether security holders will have voting
                                            or redemption rights with respect to an extension from 24 to 27 months. Please also disclose
                                            whether there are any limitations on extensions, including the number of times you may seek
                                            to extend. Also disclose the consequences to the sponsor of not completing an extension of
                                            this time period. See Item 1602(b)(4) of Regulation S-K.

We have revised the indicated disclosure in response to
the Staff’s comment.

 5. Please state the basis for your statement on page 9 that
                                            you do not believe that the fiduciary duties or contractual obligations of your officers
                                            or directors will materially affect your ability to complete your initial business combination.

We have revised the indicated disclosure in response to
the Staff’s comment.

 6. We note that you intend to effectuate your initial business
                                            combination potentially using proceeds from forward purchase agreements or backstop agreements.
                                            We also note disclosure elsewhere in the prospectus referencing possible private offerings
                                            of debt or equity, as well as forward purchase agreements and backstop arrangements. Please
                                            revise this section or include a new section within the Summary under an appropriate subheading
                                            to provide a more comprehensive discussion regarding plans to seek additional financings.
                                            For example, discuss any plans to seek additional financings in connection with meeting working
                                            capital needs in the search for the initial business combination, for the completion of an
                                            initial business combination, or in connection with the redemption of a significant number
                                            of your public shares. Please also describe how the terms of additional financings may impact
                                            unaffiliated security holders. See Item 1602(b)(5) of Regulation S-K.

We have revised the indicated disclosure in response to
the Staff’s comment.

Anticipated expenses and funding sources, page 21

 7. Please revise to clarify, if true,
                                            that the items you identify in the two bullet points may only be paid from interest on the
                                            funds held in the trust account. As drafted, the disclosure could be read to mean that the
                                            items in the bullets are in addition to withdrawals of interest to pay expenses. Please also
                                            clarify what the “permitted withdrawals” are. For example, disclose whether there
                                            are any limits on the dollar amount or percentage of interest on funds in the trust account
                                            that may be used for the purposes identified in the parenthetical.

We have revised the indicated disclosure in response to
the Staff’s comment.

    2

The Offering

Conflicts of Interest, page 30

 8. Please revise disclosure in this section to clearly state
                                            the conflicts with purchasers in the offering. In addition, please revise disclosure as follows:

 ● At the end of the carryover paragraph and first full paragraph
at the top of page 31, please explain why you do not believe that fiduciary duties or contractual obligations, or the involvement of
the sponsor, officers or directors with other SPACs would materially affect your ability to complete a business combination.

 ● In the third full paragraph on page 31, please clarify
the conflict that relates to the “different timelines” of completing your business combination given the personal and financial
interests of your directors and executive officers.

 ● Where you discuss conflicts of the sponsor, officers or
directors from owning securities in the company, please clearly disclose the price paid, including the “nominal” price paid
for the securities and the conflicts of interest in determining whether to pursue a de-SPAC transaction, and in negotiating or accepting
the terms of the de-SPAC transaction.

 ● Add disclosure of the conflicts of interest relating to
items listed under “Limited payments to insiders” such as compensation, repayment of loans and reimbursement of expenses
that will be paid to officers and directors affiliated with the sponsor upon completion of a de-SPAC transaction, as well as the potential
payment of finders, advisory, consulting or success fees for any services rendered for completion of the initial business combination.

 ● Clarify the conflicts associated with entering into a business
combination with an affiliate of your sponsor, officers or directors, as disclosed on page 133. Please refer to Item 1602(b)(7) of Regulation
S-K.

We have revised the indicated disclosure in response to
the Staff’s comment.

If we are deemed to be an investment company under the Investment
Company Act..., page 45

 9. We note your disclosures suggesting that in order to avoid
                                            having your anticipated activities not subject you to the Investment Company Act, you will
                                            hold the proceeds of the trust account only in U.S. government treasury obligations or money
                                            market funds meeting conditions under Rule 2a-7. For example, we note disclosure stating
                                            that you believe you will not be subject to the Act, and that “to this end” you
                                            will hold the trust assets in government securities. You also state that “by restricting
                                            the investment of the proceeds to these instruments” you intend to avoid being deemed
                                            an investment company. While we recognize that you also state that you may mitigate this
                                            risk by instructing the trustee to hold the funds in the trust account in cash, please revise
                                            these disclosures to clarify that even if the assets in your trust account are U.S. Government
                                            securities or shares of money market funds registered under the Investment Company Act and
                                            regulated pursuant to rule 2a-7 of that Act, you could nevertheless and at any time be considered
                                            to be operating as an unregistered investment company. Disclose that if you are found to
                                            be operating as an unregistered investment company, you may be required to change your operations,
                                            wind down your operations, or register as an investment company. Also include disclosure
                                            with respect to the consequences to investors if you required to wind down your operations
                                            as a result of this status, such as the losses of the investment opportunity in a target
                                            company, any price appreciation in the combined company, and any warrants, which would expire
                                            worthless.

We have revised the indicated disclosure in response to
the Staff’s comment.

    3

Risk Factors

The nominal purchase price paid by our sponsor for the founder
shares may result in significant dilution..., page 69

 10. Please explain to us how you calculated the implied value
                                            per share upon consummation of initial business combination in the amount of $9.53.

We respectfully inform the Staff that the implied value per share upon consummation of the initial business combination is calculated
as total funds in trust ($250,000,000) less the deferred underwriter fees ($11,875,000), for a total of $238,125,000 divided by 25,000,000
public shares.

Risk Factors

If our initial business combination involves a company organized
under the laws of the United States..., page 78

 11. We note your disclosure on page 91 that you “may
                                            withdraw interest for permitted withdrawals, including the payment of taxes.” We also
                                            note disclosure regarding the risk that a U.S. federal excise tax could be imposed on you
                                            if your business combination involves a company organized in the United States. Please clarify
                                            whether you may withdraw interest for the payment of the U.S. federal excise tax if it were
                                            imposed.

We have revised the indicated disclosure in response to
the Staff’s comment to reflect that we may not withdraw interest for the payment of any U.S. federal excise tax.

Use of Proceeds, page 82

 12. We note disclosure here and on the cover page and in the
                                            Underwriting section that $0.10 per share of underwriting compensation is in addition to
                                            the deferred portion of the compensation of $0.475, and that 50% of non-deferred compensation
                                            will be paid on the 12, 18 and 24-month anniversaries of the offering from permitted withdrawals
                                            of interest earned on the trust account. Please revise your use of proceeds table to include
                                            this 50% of non-deferred compensation as being sourced from permitted withdrawals rather
                                            than being an expense paid at closing from the proceeds of the offering.

We have revised the indicated disclosure in response to
the Staff’s comment.

Dilution, page 86

 13. Please revise the table on page 86 to explain what is
                                            represented in the first column under the heading “Offering Price of $10.00,” as
                                            well as illustrate how the NTBV per share amounts in this column were calculated.

We have revised the indicated table in response to the Staff’s comment.

 14. We note that the “Full Over-Allotment” columns
                                            of numerator calculation in the table on page 87 don’t foot due to inclusion of the overallotment
                                            liability. Please revise.

We have revised the indicated table in response to the Staff’s comment.

    4

Proposed Business

Sponsor Information, page 101

 15. In the disclosure on page 101, please state the amount
                                            of the direct and indirect material interests in the sponsor that are held by each of Messrs.
                                            Combes and Gundlach. Please see Item 1603(a)(7) of Regulation S-K.

We have revised the indicated disclosure in response to
the Staff’s comment.

 16. We note your disclosure on pages 10 and 101 that the tables
                                            set forth the payments to be received by your sponsor and its affiliates from you prior to
                                            or in connection with completion of the business combination and the securities issued or
                                            to be issued by you to your sponsor and its affiliates. Please expand the tables to address