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SEC Comment Letter for Blueport Acquisition Ltd (BPAC, BPACR, BPACU) (CIK 0002064177) (BPAC) — Jul 7, 2025

Blueport Acquisition Ltd (BPAC, BPACR, BPACU) (CIK 0002064177)
Date: July 7, 2025 · CIK: 0002064177 · Accession: 0000000000-25-007086

AI Filing Summary & Sentiment

File numbers found in text: 333-288356

Date
July 6, 2025
Author
Not clearly detected
Form
UPLOAD
Company
Blueport Acquisition Ltd (BPAC, BPACR, BPACU) (CIK 0002064177)

Letter

July 6, 2025 William Rosenstadt Chief Executive Officer Blueport Acquisition Ltd 366 Madison Ave 3rd Floor New York, NY 10017 Re:Blueport Acquisition Ltd Registration Statement on Form S-1 Filed June 26, 2025 File No. 333-288356 Dear William Rosenstadt: 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 filed June 26, 2025 Exhibits 1.Please revise the filing fee table filed as Exhibit 107 to cover all of the Class A ordinary shares underlying the rights included in the units, or advise. In this regard, we note that you are registering 7,935,000 rights but the filing fee table covers only 1,199,833 Class A ordinary shares underlying the rights. 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.

July 6, 2025 Page 2 Please contact Babette Cooper at 202-551-3396 or Kristina Marrone at 202-551-3429 if you have questions regarding comments on the financial statements and related matters. Please contact Benjamin Holt at 202-551-6614 or David Link at 202-551-3356 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc:Giovanni Caruso, Esq.

Show Raw Text
July 6, 2025
William Rosenstadt
Chief Executive Officer
Blueport Acquisition Ltd
366 Madison Ave 3rd Floor
New York, NY 10017
Re:Blueport Acquisition Ltd
Registration Statement on Form S-1
Filed June 26, 2025
File No. 333-288356
Dear William Rosenstadt:
            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 filed June 26, 2025
Exhibits
1.Please revise the filing fee table filed as Exhibit 107 to cover all of the Class A
ordinary shares underlying the rights included in the units, or advise. In this regard,
we note that you are registering 7,935,000 rights but the filing fee table covers
only 1,199,833 Class A ordinary shares underlying the rights.
            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.

July 6, 2025
Page 2
            Please contact Babette Cooper at 202-551-3396 or Kristina Marrone at 202-551-3429
if you have questions regarding comments on the financial statements and related
matters. Please contact Benjamin Holt at 202-551-6614 or David Link at 202-551-3356 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Giovanni Caruso, Esq.