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CORRESP
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 filename1.htm

 BLUE
ACQUISITION CORP.

 1601 Anita Lane

 Newport Beach, CA 92660

 June 2, 2025

 VIA
EDGAR

 Office of Real Estate and Construction

 Division of Corporation Finance

 Securities and Exchange Commission

 Washington, D.C. 20549

 Attention: Stacie Gorman

 Re:
 Blue
 Acquisition Corp./Cayman

 Registration
Statement on Form S-1

 Filed
May 14, 2025

 File
No. 333-287281

 Ladies &
Gentlemen:

 This letter sets forth the responses of Blue
Acquisition Corp., a Cayman Islands exempted company (the " Company ,"
" we ," " our "
or " us "), to the comment letter dated
May 29, 2025 received from the staff (the " Staff ")
of the Securities and Exchange Commission (the " Commission ")
concerning the Company's registration statement on Form S-1 filed via EDGAR to the Commission on May 14, 2025 (the " Registration
Statement ").

 Concurrently with the submission of this letter,
the Company is filing Amendment No. 1 to the Registration Statement (the " Amendment ")
via EDGAR to the Commission for review.

 The Staff's comments are repeated below
and are followed by the Company's responses. To the extent helpful, we have included page references in the Amendment where the
language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth
in the Amendment.

 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.

 Response : The Company acknowledges the Staff's
comment and has added disclosure on the cover page to address the adjustment to the number of founder shares which has been made to maintain
the percentage ownership of the initial shareholders at 26% as a result in the increase in the size of the offering (as well as other
adjustments, if any) and the dilutive impact of raising additional funds in response to this comment.

 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. "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.

 Response :
The Company acknowledges the Staff's comment, and has revised the disclosures concerning the business experience, and in particular,
the prior SPAC experience of General Wesley Clark and Nadim Qureshi in the two sections captioned "Our Management Team and Board
of Directors" and in the "Management" section in response to this comment.

 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

 Response : The Company acknowledges the Staff's
comment, and has revised the disclosure in both of the sections captioned "Prior SPAC Experience" to state the number of times
each SPAC has sought to extend the time to complete a business combination, the amount of time for each extension, and the redemption
levels in connection with each extension.in response to this comment.

 Management

 Special
Advisors, page 137

 4. Please revise your disclosure regarding your
special advisors to comply with Item 401(c) of Regulation S-K.

 Response : The Company acknowledges the Staff's
comment, and has provided the disclosure concerning the business experience of each special advisor on page 144 of the Amendment in response
to this comment.

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 We thank the Staff very much
for its review of the foregoing and the Amendment. If you have questions or further comments concerning the Amendment, please contact
our counsel, Lijia Sanchez of Ellenoff Grossman & Schole LLP, by telephone at (212) 370-1300 or via e-mail at lsanchez@egsllp.com.

 Sincerely,

 Blue
 Acquisition Corp.

 /s/
 Ketan Seth

 Ketan
 Seth

 Chief
 Executive Officer

 Enclosures

 cc:
 Eric
 McPhee

 Jennifer Monick

 David Link

 Lijia Sanchez

 Giovanni Caruso –
Loeb & Loeb LLP

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