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 May 1, 2025

Agustin Aldave
Chief Executive Officer
Globa Terra Acquisition Corp
Homero 109, Despacho 1602, Polanco
Ciudad de Mexico, Mexico, 11560

 Re: Globa Terra Acquisition Corp
 Registration Statement on Form S-1
 Filed April 16, 2025
 File No. 333-286585
Dear Agustin Aldave:

 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
Cover Page

1. We note you will issue one and one-fourth private placement units and
two and one-
 half restricted shares to the private investor and the sponsor per $10
invested. Please
 explain the purpose of offering these securities on different terms than
those offered to
 public investors, highlighting the discrepancy in the amount of units
plus additional
 shares that the sponsor and private investor will receive for a $10
investment, as
 compared to the public. Please address the dilutive impact this will
have on public
 investors and other associated risks, including whether the private
investor will be
 incentivized differently from public stockholders to vote in favor of an
initial business
 combination due to the terms upon which it purchased the securities or
otherwise.
2. We note that you have included disclosure regarding adjustments that you
may make
 with respect to the Class B shares if you increase or decrease the size
of the offering,
 as well as potential material dilution that may be caused by the
exercise of private
 May 1, 2025
Page 2

 placement warrants. Please add that additional dilution may occur in
connection with
 increases in the Class B shares if you increase the size of the
offering, and in
 connection with the private warrants if they are exercised on a cashless
basis.
Summary
Our Sponsor, page 6

3. We note your response to prior comments 4 and 7. Please clarify whether
Meridien
 will receive the shares immediately following the completion of the
transfer of shares
 to the private investor, or whether there are any other conditions that
must be met
 prior to distributing the shares to Meridien. Further, please clearly
state here and on
 page 122, if true, that Meridien will hold founder shares directly and
will have the
 ability to vote and dispose of the shares, subject to applicable
transfer restrictions.

4. We note your response to prior comment 5. Please revise your table to
specifically
 disclose the interests in the founder shares to be held by each
independent director and
 member of management. Please also revise your disclosure on page 121.
Please refer
 to Items 1602(b)(6) and 1603(a)(6) of Regulation S-K. Further, it
appears that
 directors and management will have a direct interest in the founder
shares. Please
 clarify, if true, that they will also have the ability to vote and
dispose of the shares,
 subject to applicable transfer restrictions.
Our Advisors, page 13

5. We note that Meridien may provide assistance during your search for a
business
 combination target. Please further elaborate on the nature of the
assistance to be
 provided and how it will be different from the services provided by
Meteora. Please
 clarify whether Meridien will receive additional fees for providing
these services, in
 addition to the shares it will receive. Further, given that both
advisors may provide
 assistance in your search for a target, please clarify whether this may
create conflicts
 between the sponsor and SPAC and how such conflicts may be resolved.
Please refer
 to Item 1603(a)(4) of Regulation S-K.
Founder Shares, page 30

6. We note your disclosure on page 33 that there will be three different
classes of
 sponsor units, with one unit further divided into Class B-1 and Class
B-2 units. Please
 disclose the number of units that will be outstanding in each category
and explain why
 certain Class B units will be subject to forfeiture and others will not.
Use of Proceeds, page 107

7. Please tell us where the Use of Proceeds table reflects the $500,000 of
compensation
 payable to Meteora upon closing of the offering under the Consulting
Services
 Agreement, or revise.
Dilution, page 111

8. Please address the following with respect to your dilution disclosure:
 The Company's tabular presentation of dilution at quartile intervals
on pages 111-
 May 1, 2025
Page 3

 112 appears to assume your maximum redemption threshold is the
entire amount
 of shares to be sold to public shareholders as part of this
offering. We further note
 your disclosure throughout your filing that you may not redeem your
public
 shares in an amount that would cause your net tangible assets to be
less than
 $5,000,001. Please tell us how you considered this redemption
restriction in your
 determination of your maximum redemption threshold for your dilution
 presentation. Please refer to Item 1602 of Regulation S-K.
 We note your disclosure that public shareholders will be entitled
to redeem their
 public shares for a pro rata portion of the amount in the trust
account, initially
 anticipated to be $10.05 per share. Please explain to us why the
"amounts paid for
 redemptions," as presented in the numerator for each redemption
scenario of your
 NTBV detailed calculations table on page 111, are calculated at
amounts
 representing more than $10.00 per share;
 Please revise page 111 to disclose the amount the Company reduced
its NTBV
 after the offering for purposes of presenting the maximum redemption
scenario.
9. Please tell us how the 1,012,500 restricted Class A shares to be sold to
the sponsor
 and Private Placement Investor are reflected in your dilution
disclosures, either inside
 or outside of the table. Please see Item 1602(c) of Regulation S-K.
Recent Accounting Standards, page F-12

10. We note your disclosure that there was no impact on the Company's
financial
 statements and disclosures as a result of your adoption of ASU 2023-07.
Please note
 that the disclosure requirements in ASC 280 - Segment Reporting applies
to all public
 entities including those that have a single reportable segment. Please
revise your
 financial statements to include the required disclosures. Refer to ASC
280-10-50-20.
Exhibits

11. In connection with your response to comment 13 in our letter dated
December 20,
 2024, please provide us supplementally with a copy of the consulting
agreement with
 Meridien and any agreement with Meteora or Meridien with respect to
purchasing
 your shares in accordance with Item 601(b)(10) of Regulation S-K.
 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.

 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 Jeffrey Lewis at 202-551-6216 or Shannon Menjivar at
202-551-3856
if you have questions regarding comments on the financial statements and
related
matters. Please contact Stacie Gorman at 202-551-3585 or Pam Long at
202-551-3765 with
any other questions.
 May 1, 2025
Page 4

 Sincerely,

 Division of Corporation Finance
 Office of Real Estate & Construction
cc: Brandon J. Bortner, Esq.
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