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CORRESP Filing

BEST SPAC I Acquisition Corp.
Date: May 23, 2025 · CIK: 0002051587 · Accession: 0001213900-25-047462

Financial Reporting Regulatory Compliance Revenue Recognition

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File numbers found in text: 333-286237

Referenced dates: April 10, 2025

Date
May 23, 2025
Author
Giovanni Caruso
Form
CORRESP
Company
BEST SPAC I Acquisition Corp.

Letter

Giovanni Caruso

Partner

345 Park Avenue Direct 212.407.4866

New York, NY 10154 Main 212.407.4000

Fax 212.937.3943

gcaruso@loeb.com

May 23, 2025

Ameen Hamady Kristina Marrone Isabel Rivera Benjamin Holt

Division of Corporation Finance

U.S. Securities & Exchange Commission

Office of Real Estate & Construction

100 F Street, NE

Washington, D.C. 20549

Re: BEST SPAC I Acquisition Corp. Registration Statement on Form S-1 Filed March 28, 2025 File No. 333-286237

Ladies and Gentlemen:

On behalf of our client, BEST SPAC I Acquisition Corp. (the "Company"), we hereby provide a response to the comments issued in a letter dated April 10, 2025 (the "Staff's Letter") regarding the above-referenced Registration Statement on Form S-1 (the "Registration Statement"). Contemporaneously, the Company is filing a revised Registration Statement via EDGAR (the "Amended Registration Statement"), which reflects the Company's responses to the comments received by the Staff and certain updated information.

In order to facilitate the review by the staff of the Securities and Exchange Commission (the "Staff") of the Amended Registration Statement, we have responded, on behalf of the Company, to the comment set forth in the Staff's Letter. The numbered paragraphs set forth below respond to the Staff's comments and correspond to the numbered paragraph in the Staff's Letter.

Registration Statement on Form S-1 filed March 28,

Note 2 - Basis of Presentation and Summary of Significant Accounting Policies Recent Accounting Pronouncements, page F-12

1. We note your disclosure that Company's management does not believe that the adoption of ASU 2023-07 will have a material impact on the audited financial statements and disclosures. Please tell us how the Company considered the additional reportable segment disclosure requirements of ASU 2023-07. Please advise or revise accordingly.

Response: In response to the Staff's comment, the Company has revised the disclosure on pages F-33-34 of the Amended Registration Statement.

U.S. Securities and Exchange Commission May 23, 2025 Page 2

Please call me at (212) 407-4866 if you would like additional information with respect to any of the foregoing. Thank you.

/s/ Giovanni Caruso

Giovanni Caruso

Partner

Show Raw Text
CORRESP
 1
 filename1.htm

 Giovanni Caruso

 Partner

 345 Park Avenue
 Direct
 212.407.4866

 New York, NY 10154
 Main
 212.407.4000

 Fax
 212.937.3943

 gcaruso@loeb.com

 May 23, 2025

 Ameen Hamady
Kristina Marrone
Isabel Rivera
Benjamin Holt

 Division of Corporation Finance

 U.S. Securities & Exchange Commission

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Re:
 BEST SPAC I Acquisition Corp.
Registration Statement on Form S-1
Filed March 28, 2025
File No. 333-286237

 Ladies and Gentlemen:

 On behalf of our client, BEST
SPAC I Acquisition Corp. (the "Company"), we hereby provide a response to the comments issued in a letter dated April 10,
2025 (the "Staff's Letter") regarding the above-referenced Registration Statement on Form S-1 (the "Registration
Statement"). Contemporaneously, the Company is filing a revised Registration Statement via EDGAR (the "Amended Registration
Statement"), which reflects the Company's responses to the comments received by the Staff and certain updated information.

 In order to facilitate the
review by the staff of the Securities and Exchange Commission (the "Staff") of the Amended Registration Statement, we have
responded, on behalf of the Company, to the comment set forth in the Staff's Letter. The numbered paragraphs set forth below respond
to the Staff's comments and correspond to the numbered paragraph in the Staff's Letter.

 Registration Statement on Form S-1 filed March 28,
2025

 Note 2 - Basis of Presentation and Summary
of Significant Accounting Policies Recent Accounting Pronouncements, page F-12

 1.
 We note your disclosure that Company's management does not believe that the adoption of ASU 2023-07 will have a material impact on the audited financial statements and disclosures. Please tell us how the Company considered the additional reportable segment disclosure requirements of ASU 2023-07. Please advise or revise accordingly.

 Response: In response to the
Staff's comment, the Company has revised the disclosure on pages F-33-34 of the Amended Registration Statement.

 U.S. Securities and Exchange Commission
 May 23, 2025
 Page 2

 Please call me at (212) 407-4866
if you would like additional information with respect to any of the foregoing. Thank you.

 /s/ Giovanni Caruso

 Giovanni Caruso

 Partner