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CORRESP
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D.
Boral Capital LLC

590
Madison Avenue,

New
York, NY 10022

September
30, 2025

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

    Re:
                                            Miluna Acquisition Corp (the “Company”)

    Registration
    Statement on Form S-1 (the “Registration Statement”)

    File
    No. 333-289973

Ladies
and Gentlemen:

In
accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), and as representative of the several underwriters
of the Company’s proposed public offering, we wish to advise you that we hereby join with the Company’s request that the
effective date of the above-referenced Registration Statement be accelerated so that the same will become effective at 5:30 p.m.,
Eastern time, on September 30, 2025, or as soon thereafter as is practicable, or at such other time as the Company or its outside counsel,
Hunter Taubman Fischer & Li LLC, requests by telephone that such Registration Statement be declared effective.

Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated
to be invited to participate in the distribution of the securities, as many copies of the proposed form of preliminary prospectus as
appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The
undersigned, as representative of the several underwriters, has complied and will continue to comply, and we have been informed by the
participating underwriters and dealers that they have complied and will continue to comply, with the requirements of Rule 15c2-8 under
the Securities Exchange Act of 1934, as amended.

    Very
    truly yours,

    D.
    Boral Capital LLC

    By:

    /s/
    Gaurav Verma

    Name:

    Gaurav
    Verma

    Title:

    Co-Head
    of Investment Banking