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August 25, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance Office of Life
Sciences

100 F Street, NE

Washington, DC 20549

    Re:
    Westin Acquisition Corp

Registration Statement on Form S-1

Filed July 23, 2025

File No. 333-288889

Ladies and Gentlemen:

On behalf of our client, Westin
Acquisition Corporation (“Westin”), we are writing to submit responses to the comments of the staff (the “Staff”)
of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Commission”) set
forth in its letter, dated August 19, 2025, relating to Westin’s Registration on Form S-1 filed July 23, 2025.

Westin is filing via EDGAR
its Registration Statement on Form S-1, which reflects certain updated information.

We have set forth below the
comments in the Staff’s letter, in bold, and the responses thereto.

Registration Statement on Form S-1 filed July
23, 2025

Cover Page

1. Please
disclose whether the closing of this offering is contingent upon Nasdaq approval of your listing application.

Response: We acknowledge the
Staff’s comment and advise that the disclosure on the cover page and pages throughout the registration statement has been
revised to address the Staff’s comment.

Prospectus Summary, page 1

2. Please
revise to highlight your dual-class capital structure within the prospectus summary section, addressing the disparate voting rights of
the Class A and Class B ordinary shares.

Response: We acknowledge the
Staff’s comment and respectfully advise that there are no disparate voting rights between the Class A and Class B ordinary
shares in this transaction. We advise that the disclosure on the cover page has been revised to address the Staff’s comment.

Competitive Strengths, page 2

3. Please disclose the
basis for your statement that your management team has significant experience in biotechnology.

Response: We acknowledge the
Staff’s comment and advise that the disclosure on pages 3 and 83 has been revised to remove the reference to
“biotechnology” to address the Staff’s comment.

Effecting a Business Combination, page 6

4. We note your disclosure
that you may seek shareholder approval to amend your amended and restated memorandum and articles of association to extend the date by
which you must consummate your initial business combination. Please expand to disclose any limitations on extensions, including the number
of times. See Item 1602(b)(4) of Regulation S-K.

Response: We acknowledge the
Staff’s comment and advise that the disclosure on page 6 and pages throughout the registration statement has been revised to
address the Staff’s comment.

Redemption Rights, page 24

5. We note your disclosure
here and elsewhere in the registration statement that pursuant to your post-offering amended and restated memorandum and articles of association
you are only required to give five 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).

Response: We acknowledge the Staff’s
comment and advise that the disclosure on pages 23 and pages throughout the registration statement has been revised to address the Staff’s
comment.

Conflicts of Interest, page 27

6. You state that each
of your directors and officers is associated with other entities that have priority and preference relative to Westin Acquisition Corp.
Please identify the entities that have these priorities and preferences.

Response: We acknowledge the Staff’s
comment and advise that the disclosure on pages 25 and 40 has been revised to address the Staff’s comment.

Dilution, page 84

7. We note your disclosure
that your net tangible book value calculations do not reflect any dilution associated with the exercises of rights as the rights are accounted
for as equity and are only exercisable following the consummation of our initial business combination. We also note that footnote four
to your denominator disclosure assumes the issuance of 833,334 public shares underlying the public rights. Please revise to consistently
disclosure whether the rights are included or excluded from your calculations.

Response: We acknowledge the Staff’s
comment and advise that the disclosure on page 74 has been revised to address the Staff’s comment.

Management, page 116

8. Please revise this section
and the prospectus summary to clearly identify any SPACs and SPAC business combinations in which your management team has participated.
In addition, for each SPAC involving members of your management team, clearly disclosure any extensions and redemption levels in connection
with any extension and/or business combination. For those SPACs that have completed a de-SPAC transaction, disclose the current trading
prices. If your management has not participated in any other SPACs or SPAC business combination, please revise to include an affirmative
statement to that effect. Refer to Item 1604(a)(3) of Regulation S-K.

Response: We acknowledge the Staff’s comment and respectfully advise that
no member of Westin’s management has participated in any other SPACs or SPAC business combinations. In addition, the disclosure
on pages 102 and 109 has been revised to address the Staff’s comment.

Conflict of Interest, page 120

9. We note your cross reference
to a risk factor titled “Since our sponsor, officers, and directors, any other holder of our initial shares may lose their entire
investment in us if our initial business combination is not completed...” However, no risk factor with this title appears in your
risk factors section. Please revise or advise.

Response: We acknowledge the Staff’s
comment and advise that the disclosure on page 42 has been revised to address the Staff’s comment.

General

10. We note disclosure
appearing throughout your prospectus discussing the risks related to investing in companies that operate in China. However, disclosure
in your prospectus summary indicates that you have no operations in China and that you will not complete an initial business combination
with a company being based in or having the majority of their operations in Greater China. We also note that your officers and directors
are residents of Singapore and Malaysia with no apparent ties to China. Please revise, wherever appropriate, to explain why the risks
associated with investing in companies that are based in or that have the majority of their operations in China apply to your company.

Response: We acknowledge the Staff’s comment and advise that the disclosure
on the cover page and pages throughout the registration statement has been revised to address the Staff’s comment.

* * * * * * *

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If you have any questions,
please feel free to contact me at (312) 662-2913. Thank you for your cooperation and prompt attention to this matter.

    Sincerely,

    /s/ Cassi Olson

    Cassi Olson

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