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 July 14, 2025

Traviss Loong Kam Seng
Chief Executive Officer
BM Acquisition Corp.
Lot 680, Jalan Batu 1 1/2, Jalan Bangi
43500 Semenyih Selangor, Malaysia

 Re: BM Acquisition Corp.
 Registration Statement on Form S-1
 Filed June 17, 2025
 File No. 333-288106
Dear Traviss Loong Kam Seng:

 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 17, 2025
Cover Page

1. Where you discuss compensation, fees, reimbursements or other cash
payments paid
 to the sponsor, officers, directors or their respective affiliates,
please revise to include
 cross-references to all related disclosures. Refer to Item 1602(a)(3) of
Regulation S-
 K.
2. When discussing the disparate voting rights, please also revise to
disclose that only
 class B ordinary shares may vote on continuing your company in a
jurisdiction outside
 of the Cayman Islands.
Conflicts of Interest, page 10

3. We note your disclosure on page 12 that you not prohibited from pursuing
an initial
 business combination with a company that is affiliated with your
sponsor, officers and
 directors or their affiliates and that you are not required to obtain a
fairness opinion
 July 14, 2025
Page 2

 from an independent entity. You also disclose on page 155, that in the
event that you
 enter into a business combination with an affiliated target, you will
obtain a fairness
 opinion from an independent entity. Please revise your registration
statement to
 reconcile these disclosures.
Offering proceeds to be held in trust, page 23

4. We note your disclosure here that except for interest earned on the
funds in the trust
 account that may be released to you to pay your tax obligations, the
proceeds held in
 the trust account will not be available to you for expenses related to
the offering or
 expenses incurred prior to a business combination. However, you indicate
on page 15
 and elsewhere that an annual limit of $100,000 of interest may be
released from
 the trust to fund your working capital requirements. Please revise here
and elsewhere
 to reconcile these disclosures or advise. Similarly, when discussing the
liquidation of
 the trust in the event you are unable to complete a business
combination, please
 clearly disclose the $100,000 from interest to pay dissolution expenses
as set forth in
 Exhibit 10.2. In this regard, we note that some places, including the
cover page, do not
 reflect such amount to be paid from the interest on the trust.
Redemption rights for public shareholders upon consummation of our initial
business
combination, page 28

5. We note your disclosure here and elsewhere in the registration
statement, as well as in
 the Amended and Restated Memorandum and Articles of Association filed as
exhibit
 3.1, that you are only required to give 10 days notice for each general
meeting. Please
 revise here and elsewhere as applicable to be consistent with the
minimum
 dissemination period required by Exchange Act Rule 14a-6(q).
Risk Factors
Risks Associated with Our Business and Securities
Trading in our securities may be prohibited under the Holding Foreign Companies
Accountable Act..., page 39

6. We note your disclosure on page 40 that your auditor is MaloneBailey,
LLP, and
 is headquartered in Houston, Texas. You further disclose that your
auditor is not
 headquartered in China or Hong Kong. However, the auditor's report and
consent
 you filed are signed by Guangdong Prouden CPAs GP, located in Guangzhou,
China.
 Please reconcile these discrepancies or advise.
Risk Factors
The nominal purchase price paid by our sponsor for the insider shares may
result in
significant dilution..., page 57

7. Please confirm the accuracy of the amounts in this risk factor, or
revise for accuracy.
Dilution
Assuming No Exercise of Over-Allotment Option, page 91

8. We note that the amounts reflected in the "Net proceeds from this
offering and sale of
 the private units, net of expenses" do not represent the correct amount.
Additionally,
 the amounts from Public Shareholders and the Total Amount in your table
at the
 July 14, 2025
Page 3

 bottom of this page do not agree with the offering. Please revise your
tables on this
 page to address these discrepancies, or advise. Additionally, please
ensure your
 tabular information throughout your filing is updated appropriately.

Management Discussion and Analysis
Liquidity and Capital Resources, page 94

9. We note your disclosure on page 94 that the factors discussed in this
section raise
 substantial doubt about your ability to continue as a going concern. We
also note your
 expert disclosure on page 186, which states that your independent
registered public
 accounting firm s report contains an explanatory paragraph expressing
substantial
 doubt about your ability to continue as a going concern, as described in
Note 1 to the
 financial statement. We are unable to locate this disclosure in Note 1.
Please reconcile
 the referenced disclosures with the accountants report on page F-2,
which does not
 contain such an explanatory paragraph, and with the disclosure on page
F-9, which
 appears to indicate that the substantial doubt about your ability to
continue as a going
 concern has been mitigated.
Principal Shareholders, page 133

10. We note your disclose here that Mr. Traviss Loong Kam Seng is the sole
member of
 your sponsor, and, as a result, holds voting and investment discretion
with respect to
 the ordinary shares held of record by the sponsor. You further disclose
that all of your
 officers, directors and your advisors are members of the sponsor. Please
revise to
 clarify this discrepancy. Please also include disclosure identifying all
of the
 controlling persons of the sponsor, all persons with a direct or
indirect material
 interest in the sponsor, and the nature and amount of their interests.
Refer to Item
 1603(a)(7) of Regulation S-K.
Exhibits

11. Please request Cayman counsel revise its opinion in Exhibit 5.1 to
remove
 inappropriate assumptions or explain these assumptions. It is not
appropriate for
 counsel to assume away material facts underlying the opinion or any
readily
 ascertainable facts. In this regard, for example, we note paragraphs
7,8, 9 and 11(b),
 (e) and (g) of Schedule 2. Refer to Section II.B.3.a of Staff Legal
Bulletin No. 19.
12. We note the disclosure on page 8 that pursuant to a letter agreement,
the sponsor,
 officers and directors agreed "to vote all ordinary shares beneficially
owned by them
 (whether acquired before, in, or after this offering) in favor of our
initial business
 combination (except that any public shares such parties may purchase in
compliance
 with the requirements of Rule 14e-5 under the Exchange Act would not be
voted in
 favor of approving the business combination transaction)." We note that
the letter
 agreement is inconsistent with such disclosure and requires such persons
to vote all
 ordinary shares owned by them in favor of a business combination. Please
reconcile.
 July 14, 2025
Page 4
13. Please revise the fee table filed as Exhibit 107 to also cover the
ordinary shares
 underlying the warrants. We note the disclosure on page 19 that you are
registering
 the ordinary shares underlying the warrants.

 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 Kellie Kim at 202-551-3129 or Shannon Menjivar at
202-551-3856 if
you have questions regarding comments on the financial statements and related
matters. Please contact Catherine De Lorenzo at 202-551-3772 or Pam Howell at
202-551-
3357 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Debbie Klis, Esq.
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