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 July 3, 2025

Shawn Matthews
Chief Executive Officer
HCM III ACQUISITION CORP.
100 First Stamford Place, Suite 330
Stamford, CT 06902

 Re: HCM III ACQUISITION CORP.
 Registration Statement on Form S-1
 Filed June 6, 2025
 File No. 333-287841
Dear Shawn Matthews:

 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. We note your disclosure that you may pay finder's fees, advisory fees,
consulting fees,
 success fees or salaries to your sponsor, officers, directors or their
affiliates. On page
 36 and elsewhere, you refer to this fee only being paid to independent
directors.
 Please revise your disclosure, as appropriate, to address this
discrepancy. Further, we
 note your disclosure in paragraph 7 with respect to how the
anti-dilution adjustment
 may result in material dilution. Please also address whether the
exercise of the private
 warrants on a cashless basis may result in a material dilution of the
purchasers' equity
 interests. Additionally, we note on page 9 you refer to shares being
adjusted so that
 "the number of Class A ordinary shares issuable upon conversion of all
Class B
 ordinary shares will equal, in the aggregate, 20% of the sum of all
ordinary shares
 issued and outstanding upon the completion of this offering, ...."
However, on the
 cover page and elsewhere, you indicate that the holders of Class B
shares will hold a
 July 3, 2025
Page 2

 25% interest upon conversion. Please revise your disclosure to address
this
 discrepancy. Please also revise your disclosure on your cover page and
pages 9 and
 113 as appropriate. Please refer to Items 1602(a)(3) of Regulation S-K,
1602(b)(6),
 and 1603 (a)(6) of Regulation S-K.
2. We note your disclosure on page 26 that you may withdraw interest for
the payment
 of taxes. We also note your disclosure on page 89 regarding the risk
that a U.S.
 federal excise tax could be imposed on you if your business combination
involves a
 company organized in the United States. Please clarify whether you may
withdraw
 interest for the payment of the U.S. federal excise tax if it were
imposed.
Our Management Team, page 3

3. Please revise to delete your duplicate disclosures in this section.
Trading commencement and separation... , page 14

4. We note your statement that Accordingly, unless you purchase at least
two units, you
 will not be able to receive or trade a whole warrant. We also note
that each unit
 contains on-third of one warrant. Please revise as appropriate.
Founder shares, page 18

5. We note disclosure on page 19, and elsewhere in the filing, that "if the
non-managing
 sponsor investors purchase all of the units for which they have
expressed to us an
 interest in purchasing or otherwise hold a substantial number of our
units, then the
 non-managing sponsor investors will potentially have different interests
than other
 public shareholders in approving our initial business combination. "
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 their placement warrants.
Conflicts of Interest, page 37

6. We note your disclosure on page 37 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.
Proposed Business
Our Management Team, page 108

7. Please ensure that you disclose each SPAC with which your sponsor,
officers and
 directors have had experience in organizing. For each prior SPAC, please
disclose any
 extensions of the time to complete the transaction and the level of
redemptions in
 connection therewith, and information concerning any completed business
 combinations, including the financing needed for the transactions and
the level of
 redemptions. See Item 1603(a)(3) of Regulation S-K. Please also revise
your
 July 3, 2025
Page 3

 disclosure on page 140 in accordance with Item 401 of Regulation S-K, as
 appropriate.
Sponsor Information, page 112

8. Please revise to specifically identify all of the persons who have a
direct or indirect
 material interest in the SPAC sponsor, as well as the nature and amount
of their
 interests, as required by Item 1603(a)(7) of Regulation S-K. Please also
revise your
 disclosure on page 143 to discuss the membership interests in the
sponsor that your
 independent directors will receive for their services as a director. See
Item 402(r)(3)
 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 Wilson Lee at 202-551-3468
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: Kevin E. Manz, Esq.
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