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 May 29, 2025

Ketan Seth
Chief Executive Officer
Blue Acquisition Corp/Cayman
1601 Anita Lane
Newport Beach, CA 92660

 Re: Blue Acquisition Corp/Cayman
 Registration Statement on Form S-1
 Filed May 14, 2025
 File No. 333-287281
Dear Ketan Seth:

 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. Unless
we note
otherwise, any references to prior comments are to comments in our April 22,
2025 letter.

Registration Statement on Form S-1
Cover Page

1. We note your revision to page 8. Please revise your disclosure on you
cover page to
 address the dilutive impact of raising additional funds. We also note
your disclosure
 on page 19, that if you increase or decrease the size of the offering,
you will take steps
 to maintain the ownership of initial shareholders at 26% of issued and
outstanding
 ordinary shares. Please revise disclosure on your cover page to address
this potential
 adjustment to the number of Class B shares held by the sponsor and its
affiliates.
Proposed Business
Our Management Team and Board of Directors, page 104

2. We note you have added disclosure regarding the experience of General
Wesley
 Clark. We note your disclosure that he served on the board of
ImmunityBio, Inc.
 May 29, 2025
Page 2

 "from February 2021 until March 9, 2021" and "since March 2021." It
appears that
 your references to ImmunityBio, Inc. are to the same entity. Please
advise or revise
 your disclosure as appropriate to clarify. Further, we note your
disclosure on page 105
 regarding the prior SPAC experience of both Wesley Clark and Nadim
Qureshi.
 Please revise to briefly address those entities in their business
experience disclosures
 as appropriate. Please revise your disclosure here and on pages 4 and
136. Please refer
 to Item 401(e) of Regulation S-K.
Prior SPAC Experience, page 105

3. We note your response to prior comment 5. Please revise your disclosure
to clarify the
 number of times each prior SPAC has sought to extend the time to
complete a
 business, the amount of time for each extension, and disclose the
redemptions levels
 in connection with each extension. See Item 1603(a)(3) of Regulation S-K
Management
Special Advisors, page 137

4. Please revise your disclosure regarding your special advisors to comply
with Item
 401(c) 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 Eric McPhee at 202-551-3693 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 David Link at
202-551-3356 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Lijia Sanchez, Esq.
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