SecProbe.io

CORRESP
 1
 filename1.htm

 D.
Boral ARC Acquisition I Corp.

 10
E. 53rd Street, Suite 3001

 New
York, NY 10022

 July
29, 2025

 VIA
EDGAR & TELECOPY

 Division
of Corporation Finance

 Office
of Technology

 U.S.
Securities & Exchange Commission

 100
F Street, NE

 Washington,
D.C. 20549

 RE:
 D. Boral ARC Acquisition I Corp. (the "Company")

 Registration Statement on Form S-1

 (File No. 333-286810) (the "Registration Statement")

 Ladies
and Gentlemen:

 The
Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness
of the Registration Statement so that such Registration Statement will become effective as of 4:00 p.m. Eastern Time on July 30, 2025,
or as soon thereafter as practicable.

 Very truly yours,

 D. Boral ARC Acquisition I Corp.

 By:
 /s/
 David Boral

 Name:
 David Boral

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 July
29, 2025

 VIA
EDGAR

 Division
of Corporation Finance

 Office
of Real Estate & Construction

 United
States Securities and Exchange Commission

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attn:
 Peter
 McPhun, Staff Attorney
 Jennifer Monick, Staff Attorney
 Pearlyne Paulemon, Staff Accountant
 David Link, Staff Accountant

 Re:
 D.
 Boral ARC Acquisition I Corp.

 Registration
Statement on Form S-1 (the "Registration Statement")

 File
No. 333-286810

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Act"), the undersigned,
for itself and the several underwriters, hereby join in the request of D. Boral ARC Acquisition I Corp. (the "Company") that
the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m.,
Eastern Time, on July 30, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Loeb
& Loeb LLP, requests by telephone that such Registration Statement be declared effective.

 Pursuant
to Rule 460 of the General Rules and Regulations under the Act, the undersigned wishes to advise you that there will be distributed to
each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, 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 advises that the several underwriters have complied and will continue to comply with the requirements of Rule 15c2-8 under
the Securities Exchange Act of 1934, as amended.

 *
* *

 [ Signature
Page Follows ]

 Very
 truly yours,

 D.
 BORAL CAPITAL LLC

 By:
 /s/
 Gaurav Verma

 Name:
 Gaurav
 Verma

 Title:
 Co-Head
 of Investment Banking

 [ Signature
Page to Underwriters' Acceleration Request Letter ]

CORRESP
 1
 filename1.htm

 July 23, 2025

 VIA EDGAR

 Division of Corporation Finance

 Office of Real Estate & Construction

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn: Peter McPhun, Staff Attorney
Jennifer Monick, Staff Attorney
Pearlyne Paulemon, Staff Accountant
David Link, Staff Accountant

 Re: D. Boral ARC Acquisition I Corp.

 Registration Statement on Form S-1 (the "Registration
Statement")

 File No. 333-286810

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Act"), the undersigned, for itself and the several underwriters, hereby join in the
request of D. Boral ARC Acquisition I Corp. (the "Company") that the effective date of the above-referenced Registration Statement
be accelerated so as to permit it to become effective at 4:00 p.m., Eastern Time, on July 29, 2025, or as soon thereafter as practicable,
or at such other time as the Company or its outside counsel, Loeb & Loeb LLP, requests by telephone that such Registration Statement
be declared effective.

 Pursuant to Rule 460 of the General Rules and Regulations under the
Act, the undersigned wishes to advise you that there will be distributed to each underwriter or dealer, who is reasonably anticipated
to participate in the distribution of the security, 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 advises that the several underwriters have complied
and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 * * *

 [ Signature Page Follows ]

 Very truly yours,

 D. BORAL CAPITAL LLC

 By:
 /s/ Gaurav Verma

 Name:
 Gaurav Verma

 Title:
 Co-Head of Investment Banking

 [ Signature Page to Underwriters' Acceleration
Request Letter ]

CORRESP
 1
 filename1.htm

 D. Boral ARC Acquisition I Corp.

 10 E. 53rd Street, Suite 3001

 New York, NY 10022

 July 23, 2025

 VIA EDGAR & TELECOPY

 Division of Corporation Finance

 Office of Technology

 U.S. Securities & Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 RE:
 D. Boral ARC Acquisition I Corp. (the "Company")

 Registration Statement on Form S-1

 (File No. 333-286810) (the "Registration Statement")

 Ladies and Gentlemen:

 The Company hereby
requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the
Registration Statement so that such Registration Statement will become effective as of 4:00 p.m. Eastern Time on July 29, 2025, or as
soon thereafter as practicable.

 Very truly yours,

 D. Boral ARC Acquisition I Corp.

 By:
 /s/ David Boral

 Name:
 David Boral

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 david
 j. levine
 Partner

 345
 Park Avenue
 New
 York, NY 10154
 Direct
 212.407.4923
 Main
 212.407.4000
 Fax
 212.937.3943
 dlevine@loeb.com

 Via
Edgar

 June
27, 2025

 Division
of Corporation Finance
U.S. Securities & Exchange Commission

 100
F Street, NE

 Washington,
D.C. 20549

 Attention:
 Pearlyne
 Paulemon

 David
 Link
 Peter
 McPhun
 Jennifer
 Monick

 Re:
 D.
 Boral ARC Acquisition I Corp.
 Amendment
 No. 1 to Registration Statement on Form S-1
 Filed
 June 11, 2025
 File
 No. 333-286810

 Dear
Ms. Paulemon:

 On
behalf of our client, D. Boral ARC Acquisition I Corp. (the " Company "), we hereby provide a response to the
comments issued in a letter dated June 26, 2025 (the " Staff's Letter ") regarding the Company's
registration statement on Form S-1 that was filed by the Company on June 11, 2025 (the " Registration Statement ").
Concurrently with the filing of this letter, the Company is filing an amendment to the Registration Statement (the " Amended
Registration Statement ") via EDGAR for review in accordance with the procedures of the Securities and Exchange Commission.

 In
order to facilitate the review by the staff of the Securities and Exchange Commission (the " Staff ") of the
Amended Registration Statement, we have responded, on behalf of the Company, to the comments set forth in the Staff's Letter on
a point-by-point basis. The numbered paragraphs set forth below respond to the Staff's comments and correspond to the numbered
paragraph in the Staff's Letter.

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

 Cover
page

 1.
 In
 the paragraph starting with "As more fully discussed in "Management - Conflicts of Interest ...", please
 revise to briefly address the reimbursement of any out-of-pocket expenses related to identifying, investigating and completing an
 initial business combination.

 Response:
The Company has revised the disclosure on the cover page of the Amended Registration Statement to address the Staff's comment.

 Sponsor
Information , page 13

 2.
 We
 note your response to prior comment 5. We note that your CEO is also the CEO of D. Boral Capital, the sole book-running manager and
 representative of the underwriters, beneficially owns interests that contain solely of the representative shares and David Boral
 is a deemed to be a promoter of the company as disclosed on page 156. Please revise the compensation tables on pages 13 and 112 to
 disclose the compensation of representative shares in connection with this offering or advise us in more detail why the representative
 shares should not be disclosed in the compensation tables. See Item 1602(b)(6) of Regulation S-K.

 Response:
The Company has revised the disclosure on pages 13 and 112 of the Amended Registration Statement to address the Staff's comment.

 Exhibits

 3.
 We
 note your auditor's consent at exhibit 23.1. Please have your auditor revise their consent to remove the reference to "post-effective"
 when referring to this amendment. Further, please have your auditor revise their consent to include the correct name of the registrant.

 Response:
The Company advises the Staff that the auditor has revised exhibit 23.1 to the Amended Registration Statement to address the Staff's
comment.

 Thank
you very much for your time and attention to this matter and please call me at 212-407-4923 if you have any questions or would like additional
information with respect to any of the foregoing.

 Sincerely,

 /s/
 David J. Levine

 David
 J. Levine

 Partner

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 26, 2025

David Boral
Chief Executive Officer
D. Boral ARC Acquisition I Corp.
10 E. 53rd Street, Suite 3001
New York, NY 10022

 Re: D. Boral ARC Acquisition I Corp.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed June 11, 2025
 File No. 333-286810
Dear David Boral:

 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. Unless
we note
otherwise, any references to prior comments are to comments in our May 23, 2025
letter.

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

1. In the paragraph starting with As more fully discussed in
Management Conflicts
 of Interest , please revise to briefly address the reimbursement
of any out-of-
 pocket expenses related to identifying, investigating and completing an
initial
 business combination.
Sponsor Information , page 13

2. We note your response to prior comment 5. We note that your CEO is also
the CEO
 of D. Boral Capital, the sole book-running manager and representative of
the
 underwriters, beneficially owns interests that contain solely of the
representative
 shares and David Boral is a deemed to be a promoter of the company as
disclosed on
 June 26, 2025
Page 2

 page 156. Please revise the compensation tables on pages 13 and 112 to
disclose the
 compensation of representative shares in connection with this offering
or advise us in
 more detail why the representative shares should not be disclosed in the
compensation
 tables. See Item 1602(b)(6) of Regulation S-K.
Exhibits

3. We note your auditor's consent at exhibit 23.1. Please have your auditor
revise their
 consent to remove the reference to "post-effective" when referring to
this amendment.
 Further, please have your auditor revise their consent to include the
correct name of
 the registrant.
 Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please contact Pearlyne Paulemon at 202-551-8714 or David Link at
202-551-3356
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: David Levine
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 david j. levine Partner

 345 Park Avenue New York, NY 10154

 Direct 212.407.4923
 Main 212.407.4000
 Fax 212.937.3943
 dlevine@loeb.com

 Via Edgar

 June 10, 2025

 Division of Corporation Finance U.S. Securities & Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Attention:
 Pearlyne Paulemon

 David Link
 Peter McPhun
 Jennifer Monick

 Re:
 D. Boral ARC Acquisition I Corp. Registration Statement on Form S-1 Filed April 29, 2025 File No. 333-286810

 Dear Ms. Paulemon:

 On behalf of our client, D. Boral ARC Acquisition I Corp. (the " Company "), we hereby provide a response to the comments issued in a letter dated May 23, 2025 (the " Staff's Letter ") regarding the Company's registration statement on Form S-1 that was filed by the Company on April 29, 2025 (the " Registration Statement "). Concurrently with the submission of this letter, the Company is filing an amendment to the Registration Statement (the " Amended Registration Statement ") via EDGAR for review in accordance with the procedures of the Securities and Exchange Commission.

 In order to facilitate the review by the staff of the Securities and Exchange Commission (the " Staff ") of the Amended Registration Statement, we have responded, on behalf of the Company, to the comments set forth in the Staff's Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff's comments and correspond to the numbered paragraph in the Staff's Letter.

 Registration Statement on Form S-1

 Cover Page

 1.
 Please revise your cross-references to highlight by prominent type or in another manner to all relevant sections in the prospectus for disclosure related to each of compensation, dilution, and material conflicts of interest, as required by Item 1602(a)(3),(4), and (5) of Regulation S-K.

 Response: The Company has revised the disclosure on the cover page of the Amended Draft Registration Statement to address the Staff's comment.

 Prior SPAC Experience, page 6

 2.
 We note you indicate that members of your management team have successfully identified and closed five SPAC business combinations. Please revises to address the three additional SPAC business combinations associated with your management team.

 Response: The Company has revised the disclosure on pages 3 and 108 of the Amended Registration Statement to address the Staff's comment.

 Sponsor Information, page 11

 3.
 We note the lock-up period with the underwriter. Please revise the tables beginning on pages 13 and 110 to include the lock-up period. See Item 1603(a)(9) of regulation S- K.

 Response: The Company has revised the disclosure on pages 16 and 114 of the Amended Registration Statement to address the Staff's comment.

 4.
 Please revise your compensation table on pages 11 and 108 to reference the potential payments that may be made to your sponsor, officers or directors, its affiliates or promoters of finder's, advisory, consulting or success fees for their services rendered prior to or in connection with the completion of the initial business combination. Please also disclose the anti-dilution adjustment of the founder shares in the table. See Item 1602(b)(6) of Regulation S-K.

 Response: The Company has revised the disclosure on the cover page and on pages 12 and 110 of the Amended Registration Statement to address the Staff's comment.

 5.
 We note that D. Boral Capital, the sole book-running manager and representative of the underwriters, is an affiliate of your Sponsor. Please revise the compensation tables on pages 11 and 108 to disclose the compensation of representative shares in connection with this offering. See Item 1602(b)(6) of Regulation S-K.

 Response: The Company advises
the Staff that D. Boral Capital is not an affiliate of the Sponsor and therefore the representative shares are not required to be
disclosed in the compensation table under Item 1602(b)(6). The term "affiliate" is defined in Rule 405 under the Act as
a "person that directly, or indirectly through one or more intermediaries, controls, is controlled by, or is under common
control with," the person specified. The term "control" is defined in Rule 405 under the Act as "the
possession, direct or indirect, of the power to direct or cause the direction of the management and policies of a person, whether
through the ownership of voting securities, by contract, or otherwise." D. Boral Capital is not an affiliate of the Sponsor
pursuant to this definition. D. Boral Capital is not a member or manager of the Sponsor and lacks the power to, directly or
indirectly, affect the Sponsor's management, operation or its policies.

 Dilution, page 98

 6.
 We note your tabular dilution disclosure on page 99. Specifically, we note the amounts you have reflected within the redemptions line item. Please revise the amounts within this line item for accuracy.

 Response: The Company has revised the disclosure on page 99 of the Amended Registration Statement to address the Staff's comment.

 Signatures, page II-4

 7.
 Please revise to have the registration statement signed by a majority of your board of directors. Refer to Instruction 1 to the Signatures section of Form S-1.

 Response: The Company has revised page II-4 of the Amended Registration Statement to address the Staff's comment and further advises the Staff that, as of the date hereof, the Company has two directors, Mr. Boral and Mr. Darwin, both of whom have signed the Amended Registration Statement.

 2

 Thank you very much for your time and attention to this matter and please call me at 212-407-4923 if you have any questions or would like additional information with respect to any of the foregoing.

 Sincerely,

 /s/ David J. Levine

 David J. Levine

 Partner

 3

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 23, 2025

David Boral
Chief Executive Officer
D. Boral ARC Acquisition I Corp.
10 E. 53rd Street, Suite 3001
New York, NY 10022

 Re: D. Boral ARC Acquisition I Corp.
 Registration Statement on Form S-1
 Filed April 29, 2025
 File No. 333-286810
Dear David Boral:

 We have reviewed your 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.

Registration Statement on Form S-1
Cover Page

1. Please revise your cross-references to highlight by prominent type or in
another
 manner to all relevant sections in the prospectus for disclosure related
to each of
 compensation, dilution, and material conflicts of interest, as required
by Item
 1602(a)(3),(4), and (5) of Regulation S-K.
Prior SPAC Experience, page 6

2. We note you indicate that members of your management team have
successfully
 identified and closed five SPAC business combinations. Please revises to
address the
 three additional SPAC business combinations associated with your
management team.
Sponsor Information, page 11

3. We note the lock-up period with the underwriter. Please revise the
tables beginning on
 May 23, 2025
Page 2

 pages 13 and 110 to include the lock-up period. See Item 1603(a)(9) of
regulation S-
 K.
4. Please revise your compensation table on pages 11 and 108 to reference
the potential
 payments that may be made to your sponsor, officers or directors, its
affiliates or
 promoters of finder's, advisory, consulting or success fees for their
services rendered
 prior to or in connection with the completion of the initial business
combination.
 Please also disclose the anti-dilution adjustment of the founder shares
in the table. See
 Item 1602(b)(6) of Regulation S-K.
5. We note that D. Boral Capital, the sole book-running manager and
representative of
 the underwriters, is an affiliate of your Sponsor. Please revise the
compensation tables
 on pages 11 and 108 to disclose the compensation of representative
shares in
 connection with this offering. See Item 1602(b)(6) of Regulation S-K.
Dilution, page 98

6. We note your tabular dilution disclosure on page 99. Specifically, we
note the
 amounts you have reflected within the redemptions line item. Please
revise the
 amounts within this line item for accuracy.
Signatures, page II-4

7. Please revise to have the registration statement signed by a majority of
your board of
 directors. Refer to Instruction 1 to the Signatures section of Form S-1.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please contact Pearlyne Paulemon at 202-551-8714 or David Link at
202-551-3356
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: David Levine
</TEXT>
</DOCUMENT>