SecProbe.io

September 29, 2025
Eli Baker
Chief Executive Officer
Infinite Eagle Acquisition Corp.
955 Fifth Avenue
New York, NY 10075
Re:Infinite Eagle Acquisition Corp.
Draft Registration Statement on Form S-1
Submitted September 4, 2025
CIK No. 0002084396
Dear Eli Baker:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement and non-public draft submissions on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 submitted September 4, 2025
Summary
Our Sponsor, page 8
1.Outside of the table on pages 8-10, please expand to disclose the extent to which the
conversion of loans into private placement shares of the post-business combination
entity may result in a material dilution of the purchasers' equity interests. See Item
1602(b)(6) of Regulation S-K.
Payments to insiders, page 30
2.Please revise to clarify the aggregate amount your sponsor may loan to you for
offering-related and organizational expenses, which elsewhere you state is $400,000
but here you state is $1,000,000.

September 29, 2025
Page 2
Use of Proceeds, page 80
3.We note you report $1,509,000 of Legal, accounting, due diligence, travel, and other
expenses in connection with any business combination, in your Use of Proceeds
disclosures. However, in your Liquidity and Capital Resources disclosures, on page
89, you state these costs will amount to $2,509,000. Please revise to provide consist
disclosures throughout the filing as needed.
Management
Conflicts of Interest, page 128
4.We note your disclosure that you not believe the fiduciary duties or contractual
obligations of your officers or directors will materially affect your ability to complete
your initial business combination because the other entities to which your officers and
directors currently owe fiduciary duties or contractual obligations are not themselves
in the business of engaging in business combinations. However, we also note that
each of your officers and directors is currently also an officer or director of Bold
Eagle Acquisition Corp., which is a special purpose acquisition company. Therefore,
please revise or advise to reconcile.
            Please contact Babette Cooper at 202-551-3396 or Isaac Esquivel at 202-551-3395 if
you have questions regarding comments on the financial statements and related matters.
Please contact Benjamin Holt at 202-551-6614 or Pam Howell at 202-551-3357 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Daniel Nussen