SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 1, 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.
 Amended Registration Statement on Form S-1
 Filed July 25, 2025
 File No. 333-288106
Dear Traviss Loong Kam Seng:

 We have reviewed your amended 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.

Form S-1 Amendment No. 1 filed July 25, 2025
Cover Page

1. We note the revised disclosure on the cover page and elsewhere that in
connection
 with a business combination or extension of the time period to complete
a business
 combination, public shareholders may redeem their shares "at a per-share
price . . .
 equal to the aggregate amount then on deposit in the trust account
described below,
 including interest (net of taxes payable and less interest to pay
dissolution expenses up
 to $100,000), divided by the number of then issued and outstanding
public shares."
 Please advise why you would allocate funds from the trust for
dissolution expenses in
 the event of a business combination or extension and how such provision
is consistent
 with Nasdaq Rule IM-5101-2(d), which says "public Shareholders voting
against a
 business combination must have the right to convert their shares of
common stock
 into a pro rata share of the aggregate amount then in the deposit
account (net of taxes
 August 1, 2025
Page 2

 payable and amounts distributed to management for working capital
purposes)."
 Please also reconcile such references to dissolution expenses from the
interest with the
 disclosure on page 87 that you will pay the costs of liquidating the
trust account from
 your remaining assets outside of the trust account.
Use of Proceeds, page 84

2. We refer to footnote 5 on page 85. Please clarify the specific amount
included for
 ARC Group Limited s services within the total offering expenses of
$1,158,290, and
 consider revising the disclosure to clearly present this information.
Underwriting, page 177

3. We refer to the per-unit commission of $0.10 and the total expense
payable to the
 underwriters of $600,000, as presented in your underwriters
commissions table.
 Footnote (1) indicates that the commission payable to the underwriters is
$0.10 per
 unit upon the consummation of this initial public offering, with an
additional $0.10
 per unit payable upon the consummation of an initial business
combination.
 Additionally, your estimated offering expenses are stated as $986,000,
which is
 inconsistent with the offering expenses disclosed in the Use of Proceeds
table on page
 84. Please reconcile these discrepancies or revise, as appropriate.
 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.
</TEXT>
</DOCUMENT>