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 April 16, 2025

Josef Valdman
Chief Executive Officer
Perimeter Acquisition Corp. I
6060 N. Central Express Way, Suite 500
Dallas, TX 75204

 Re: Perimeter Acquisition Corp. I
 Registration Statement on Form S-1
 Filed March 20, 2025
 File No. 333-285974
Dear Josef Valdman:

 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. Please describe on the cover page, the summary, and elsewhere as
applicable the anti-
 dilution adjustments that may result in the issuance of additional
securities to the
 sponsor, its affiliates, and promoters in connection with any change in
the size of the
 offering. In that regard, we note your disclosure on pages 22, 87, and
elsewhere that if
 you increase or decrease the size of the offering pursuant to Rule
462(b) under the
 Securities Act, you will effect a share capitalization or other
mechanism with respect
 to your Class B shares so as to maintain the ownership of founder shares
by the initial
 shareholders, on an as-converted basis, at approximately 20% of your
issued and
 outstanding ordinary shares upon consummation of the offering. Please
refer to Items
 1602(a)(3) and 1602(b)(6) of Regulation S-K.
 April 16, 2025
Page 2
Summary, page 1

2. Please include a discussion of any prior SPAC experience of your
management team,
 your sponsor, or affiliates. For example, please include details such as
any completed
 business combinations and related redemption levels, and any possible
liquidations.
 Please refer to Item 1603(a)(3) of Regulation S-K.
Principal Shareholders, page 138

3. Please revise the appropriate section or sections of your document to
include a
 description of the material roles and responsibilities of the SPAC
sponsor and any of
 its affiliates in directing and managing your company's activities. In
that regard we
 note your footnote disclosure 3 and 5 on page 138. Please refer to Item
1603(a)(4) of
 Regulation S-K.
4. Please disclose all persons who have a direct and material interest in
the SPAC
 sponsor. We note your disclosure that Gamma Asset Management LLC has a
 membership interest and a certain percentage of the economic rights
attributable to the
 sponsor, and your statement that Gamma International Bank is a
"strategic investor in
 [y]our sponsor." Refer to Item 1603(a)(7) of Regulation S-K. To the
extent an entity's
 interest in the sponsor is direct and material, please disclose the
natural person(s) who
 have voting or investment control over the shares held by the entity.

 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 William Demarest at 202-551-3432 or Mark Rakip at
202-551-3573 if
you have questions regarding comments on the financial statements and related
matters. Please contact Catherine De Lorenzo at 202-551-3772 or Mary Beth
Breslin at 202-
551-3625 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Daniel Forman, Esq.
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