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SEC Company Response from Harvard Ave Acquistion Corp (HAVA, HAVAR, HAVAU) (CIK 0002042460) (HAVA) — Sep 29, 2025

Harvard Ave Acquistion Corp (HAVA, HAVAR, HAVAU) (CIK 0002042460)
Date: Sept. 29, 2025 · CIK: 0002042460 · Accession: 0001213900-25-092643

AI Filing Summary & Sentiment

File numbers found in text: 333-284826

Date
September 29, 2025
Author
D. BORAL CAPITAL LLC
Form
CORRESP
Company
Harvard Ave Acquistion Corp (HAVA, HAVAR, HAVAU) (CIK 0002042460)

Letter

September 29, 2025

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

Attention: William Demarest

Wilson Lee

Benjamin Holt

Jeffrey Gabor

Re:

Harvard Ave Acquisition Corporation

Registration Statement on Form S-1, as amended

Initially Filed on February 11, 2025

File No. 333-284826

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned hereby joins in the request of Harvard Ave Acquisition Corporation that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m., Eastern Time, on September 30, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Robison & Cole LLP, request by telephone that such Registration Statement be declared effective.

Pursuant to Rule 460 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

Very truly yours,
D. BORAL CAPITAL LLC

Show Raw Text
CORRESP
1
filename1.htm

September 29, 2025

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

Attention: William Demarest

Wilson Lee

Benjamin Holt

Jeffrey Gabor

    Re:

    Harvard Ave Acquisition Corporation

    Registration Statement on Form S-1, as amended

    Initially Filed on February 11, 2025

    File No. 333-284826

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the “Act”), the undersigned hereby joins in the request of Harvard Ave Acquisition Corporation
that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m.,
Eastern Time, on September 30, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel,
Robison & Cole LLP, request by telephone that such Registration Statement be declared effective.

Pursuant to Rule 460 of the General Rules and Regulations of the Securities
and Exchange Commission under the Securities Act of 1933, as amended, please be advised that there will be distributed to each underwriter
or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary
prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advises that it has complied and will continue to comply
with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

    Very truly yours,

    D. BORAL CAPITAL LLC

    By:
    /s/ Stephanie Hu

    Name:
    Stephanie Hu

    Title:
    Co-Head of Investment Banking

[Signature Page to Underwriter’s
Acceleration Request Letter]