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 January 12, 2026

Eli Baker
Chief Executive Officer
Infinite Eagle Acquisition Corp.
955 Fifth Avenue
New York, NY 10075

 Re: Infinite Eagle Acquisition Corp.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed January 12, 2026
 File No. 333-291679
Dear Eli Baker:

 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.

Amendment No. 1 to Registration Statement on Form S-1 filed January 12, 2026
Risk Factors
General Risk Factors, page 75

1. Please revise to restore your risk factor related to the 1% U.S. federal
excise tax on
 stock buybacks.
Exhibits

2. Please request Cayman Islands counsel to revise its legal opinion filed
as Exhibit
 5.1 to remove assumption (vii), which assumes material facts underlying
the opinion.
 Refer to Section II.B.3.a of Staff Legal Bulletin No. 19.
3. Please request New York counsel to revise its legal opinion filed as
Exhibit 5.2 to
 cover all of the securities being registered and to remove inappropriate
assumptions.
 In this regard, we note that you are registering 34,500,000 units;
however, the opinion
 January 12, 2026
Page 2

 appears to cover only 30,000,000 units. We also note, on page 2,
paragraph 3, the
 assumptions in clauses (ii), (iv), and (v), which appear overly broad
and assume
 material facts underlying the opinion or readily ascertainable facts in
relation to the
 company and/or New York law. Refer to Section II.B.3.a of Staff Legal
Bulletin No.
 19.
4. Please revise the filing fee table to register the Class A ordinary
shares included as
 part of the units and to register the Eagle Share Rights included as
part of the units.
Signatures, page II-5

5. Please include the signatures of your principal financial officer, your
controller or
 principal accounting officer, and at least a majority of the board of
directors. See
 Instruction 1 to Signatures to Form S-1.
 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
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