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 April 4, 2025

Donald J. Puglisi
Managing Director
Axiom Intelligence Acquisition Corp 1
45 Pall Mall
London SW1Y 5JG
United Kingdom

 Re: Axiom Intelligence Acquisition Corp 1
 Draft Registration Statement on Form S-1
 Submitted March 10, 2025
 CIK No. 0002057030
Dear Donald J. Puglisi:

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

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1
Cover Page

1. Please revise paragraph 8 to disclose whether compensation and
securities issuance
 may result in a material dilution of the purchasers' equity interests.
Please refer to
 Item 1602(a)(3) of Regulation S-K.
Summary, page 1

2. We note your disclosure on page 61 that you may seek additional
financing. Please
 revise your summary to provide the information required by Item
1602(b)(5) of
 Regulation S-K.
 April 4, 2025
Page 2
3. Please revise your summary section to provide the tabular and related
compensation
 disclosure required by Item 1602(b)(6) of Regulation S-K.
The Offering
Founders Shares, page 12

4. We note disclosure on page 14 and elsewhere in the filing that if the
non-managing
 sponsor investors purchase all of the units for which they have
expressed interest or
 otherwise hold a substantial number of units, then they will potentially
have different
 interests than other public shareholders. Please revise to clarify that
regardless of the
 number of units they purchase, non-managing sponsor investors will have
different
 interests than other public shareholders in that they will be
incentivized to vote for a
 business combination due to their indirect interest in founder shares
and private units.
Ability to extend time to complete business combination, page 19

5. Please provide all of the disclosure required by Item 1602(b)(4) of
Regulation S-K
 including whether there are any limitations on the number of extensions,
including the
 number of times. Also disclose the consequences to the sponsor of not
completing an
 extension of this time period.
Conflicts of Interest, page 33

6. We note your disclosure on page 34 that your "sponsor, officers, or
directors may
 sponsor or form other special purpose acquisition companies similar to
[yours] or may
 pursue other business or investment ventures during the period in which
[you] are
 seeking an initial business combination." Please clarify how
opportunities to acquire
 targets will be allocated among SPACs. Please make similar revisions to
your
 disclosure on page 146. Please refer to Items 1602(b)(7) and 1603(b) of
Regulation S-
 K.
Dilution, page 93

7. Please expand your narrative disclosure to include a discussion of each
material
 potential source of future dilution. Your revisions should address, but
not be limited
 to, the Share Rights and shares that may be issued in connection with
the conversion
 of the Working Capital Loans. Reference is made to Item 1602(c) of
Regulation S-K.
Proposed Business, page 101

8. We note your disclosure on page 116 that you have not "contacted any of
the
 prospective target businesses that [your] management team in their prior
SPACs had
 considered and rejected as target businesses to acquire." Please provide
the disclosure
 required by 1603(a)(3) of Regulation S-K or advise. Please also revise
your disclosure
 regarding your management's experience as appropriate.
 April 4, 2025
Page 3

 Please contact Frank Knapp at 202-551-3805 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please contact Stacie Gorman at 202-551-3585 or Jeffrey Gabor at
202-551-2544
with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Real Estate &
Construction
cc: Joshua N. Englard, Esq.
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