SecProbe.io

CORRESP
 1
 filename1.htm

 January 12, 2026

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street NE

 Washington, D.C. 20549

 Attn: Benjamin Holt
Pam Howell
Babette Cooper
Isaac Esquivel

 Re: Infinite Eagle Acquisition Corp.

 Amendment No. 1 to Registration Statement on
Form S-1

 Filed January 12, 2026

 File No. 333-291679

 Ladies and Gentlemen:

 On behalf of our client, Infinite
Eagle Acquisition Corp., a Cayman Islands exempted company (the "Company"), we are writing to submit the Company's responses
to the comments of the staff of the Division of Corporation Finance of the United States Securities and Exchange Commission (the "Staff")
with respect to the above-referenced Amendment No. 1 to the Registration Statement on Form S-1 filed on January 12, 2026 (the "Amended
Registration Statement"), contained in the Staff's letter dated January 12, 2026 (the "Comment Letter").

 The Company has filed via
EDGAR its Amendment No. 2 to the Registration Statement on Form S-1 ("Second Amended Registration Statement"), which reflects
the Company's responses to the comments received by the Staff and certain updated information. For ease of reference, each comment
contained in the Comment Letter is printed below in bold and is followed by the Company's response. All page references in the responses
set forth below refer to page numbers in the Second Amended Registration Statement. Capitalized terms used but not defined herein have
the meanings set forth in the Second Amended Registration Statement.

 January 12, 2026

 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 factors related to the 1% U.S. federal excise tax on stock buybacks.

 Response : The Company has restored
such risk factor on page 75.

 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.

 Response : The Company has re-filed
the revised legal opinion of Cayman Islands counsel as Exhibit 5.1 in response to the comment of the Staff.

 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 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.

 Response : The Company has re-filed
the revised legal opinion of New York counsel as Exhibit 5.2 in response to the comments of the Staff.

 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.

 Response : The Company has revised
and re-filed the filing fee table to register the Class A ordinary shares and 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.

 Response : The Company has revised
the signature page to included such signatures.

 Please do not hesitate to
contact Joel Rubinstein at (212) 819-7642 or Daniel Nussen at (213) 620-7796 of White & Case LLP with any questions or comments regarding
this letter.

 Best regards,

 /s/ White & Case LLP

 cc: Eli Baker, Infinite Eagle Acquisition Corp.