SecProbe.io

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 May 20, 2025

Edward Wang
Chief Executive Officer
Lake Superior Acquisition Corp
521 Fifth Avenue 17th Floor
New York, NY 10175

 Re: Lake Superior Acquisition Corp
 Registration Statement on Form S-1
 Filed May 9. 2025
 File No. 333-287114
Dear Edward Wang:

 We have reviewed your registration statement and have the following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-1 filed May 9, 2025
Risk Factors, page 35

1. We note your response to prior comment 4 and reissue in part. Please
revise your tax-
 related risk factor disclosure to address the uncertainties and material
risks related to
 rights ownership referenced in the tax section.
Principal Shareholders, page 133

2. We note your response to prior comment 2. Please revise footnote 3,
which indicates
 the sponsor will own 3,648,333 shares following the offering, for
consistency with
 information in the table. Further disclose, by footnote or otherwise,
the number of
 shares that the sponsor will hold following the offering if the
overallotment option is
 exercised, taking into account the non-forfeiture of shares and the
additional private
 placement units to be purchased.
 May 20, 2025
Page 2
3. Your table of beneficial ownership indicates that Edward Cong Wang owns
3,698,333
 shares prior to the offering. Please add footnote disclosure to clarify,
if true, that these
 represent 3,498,333 shares held by the sponsor and 50,000 shares
transferred from the
 sponsor and held directly by Mr. Wang. Include analogous disclosure
regarding post-
 offering ownership. Additionally revise the following disclosure to
refer to Mr. Wang
 as appropriate: "Our Sponsor will transfer in an aggregate of 185,000
founder shares)
 to each of Raymond J. Gibbs, Manuel C. Menendez III, and Stephen Yas
upon the
 effectiveness of the registration statement of which this prospectus
forms a part."
Description of Securities, page 139

4. The second bullet point refers to 3,713,333 Class B shares held by your
initial
 shareholders and their permitted transferees following the offering.
However, this
 appears inconsistent with disclosure elsewhere indicating that 3,833,333
Class B
 founder shares are currently outstanding, and 500,000 of such shares
will be forfeited
 if the overallotment option is not exercised, leaving 3,648,333 Class B
shares held by
 the sponsor and permitted transferees. Please revise to reconcile; in
this regard, we
 note that the 380,000 Class A shares underlying private placement units
are not taken
 into account.
Legal Matters, page 179

5. We note disclosure that Loeb & Loeb LLP and Forbes Hare LLP are both
passing
 upon the validity of the shares. Please revise to reflect the opinions
filed as Exhibits
 5.1 and 5.2.
Financial Statements
General, page F-1

6. Please revise to provide updated interim financial statements in your
next
 amendment.
Signatures, page II-4

7. Please revise to identify the individual signing in the capacity of your
principal
 accounting officer or controller. Refer to the Instructions to
Signatures on Form F-1.
Exhibits

8. Please request counsel to revise the legal opinion filed as Exhibit 5.1
to clearly cover
 the shares that will be issued upon the exercise of rights following
completion of the
 business offering. In addition, please request counsel to revise the
penultimate
 paragraph of the opinion, as this appears to limit reliance. Refer to
Section II.B.3.d of
 Staff Legal Bulletin 19.
9. Please resubmit Exhibit 10.1 in a format that is text-searchable.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.
 May 20, 2025
Page 3

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Beverly Singleton at 202-551-3328 or Hugh West at
202-551-3872 if
you have questions regarding comments on the financial statements and related
matters. Please contact Erin Donahue at 202-551-6063 or Jennifer Angelini at
202-551-3047
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Giovanni Caruso
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