SecProbe.io

CORRESP
 1
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 Bluerock Acquisition Corp.

 919 Third Avenue

 New York, New York 10022

 December 8, 2025

 VIA EDGAR

 Katherine Bagley

 Division of Corporation Finance

 Office of Industrial Applications and Services

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, DC 20549-3233

 Re:
 Bluerock Acquisition Corp.

 Registration Statement on Form S-1

 Filed November 6, 2025, as amended

 File No. 333-291337

 Dear Ms. Bagley:

 Pursuant to Rule 461 of the
rules and regulations promulgated under the Securities Act of 1933, as amended, Bluerock Acquisition Corp. respectfully requests 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 December 10, 2025, or as soon thereafter as practicable.

 Please call Elliott Smith
of Perkins Coie LLP at (212) 261-6847 to provide notice of the effectiveness of the Registration Statement.

 [ Signature Page Follows ]

 Very truly yours,

 By:
 /s/ Jordan B. Ruddy

 Name:
 Jordan B. Ruddy

 Title:
 President

 cc: Elliott Smith, Perkins Coie LLP

 [ Signature Page to Acceleration Request ]

CORRESP
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 CANTOR FITZGERALD & CO.

 New York, New York 10022

 December 8, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Bluerock Acquisition Corp.

 Registration Statement on Form S-1, as amended

 Filed November 6, 2025, as amended

 File No. 333-291337

 Ladies and Gentlemen:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended (the "Act"), the undersigned hereby joins in the request of Bluerock Acquisition Corp.
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.
ET on December 10, 2025, or as soon as thereafter practicable.

 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 may 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
it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities and Exchange Act of 1934, as amended.

 Very truly yours,

 CANTOR FITZGERALD & CO.

 By:
 /s/ David Batalion

 Name:
 David Batalion

 Title:
 Managing Director, Investment Banking

CORRESP
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 Perkins Coie LLP
 1155 Avenue of the Americas
 22nd Floor
 New York, NY 10036-2711

 T. +1.212.262.6900
 F. +1.212.977.1649
 perkinscoie.com

 November 6, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial Applications and Services

 100 F Street NE

 Washington, D.C. 20549

 Attention:
 Tayyaba Shafique

 Michael Fay

 Re:
 Bluerock Acquisition Corp.

 Draft Registration Statement on Form S-1

 Submitted August 29, 2025

 CIK No. 0002081532

 Ladies and Gentlemen:

 On behalf of our client, Bluerock
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 Draft Registration Statement on Form S-1 (the " Draft Registration
Statement "), contained in the Staff's letter dated September 24, 2025 (the " Comment Letter ").

 The Company has filed via
EDGAR the Registration Statement (" 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 Company's responses set forth below refer
to page numbers in the Registration Statement. Capitalized terms used but not defined herein have the meanings set forth in the Registration
Statement.

 Draft Registration Statement on Form S-1 submitted
August 29, 2025

 Summary, page 1

 1. Please revise your summary to disclose, as you do in your risk factors, that significant competition
may impact the attractiveness of the acquisition terms that the SPAC will be able to negotiate with a potential target company.

 Response : The Company acknowledges
the comments of the Staff and has revised the disclosure on page 44.

 United States Securities and Exchange Commission

 November 6, 2025

 Our Company, page 3

 2. We note your statement that your directors
 and officers, or their respective affiliates, "may in the future" become affiliated
 with other SPACs that may have acquisition objectives that are similar to yours. Please expand
 on this disclosure to more explicitly describe the experience of the SPAC sponsor, its affiliates,
 and any promoters in organizing special purpose acquisition companies and the extent to which
 the SPAC sponsor, its affiliates, and the promoters are involved in other special purpose
 acquisition companies. Please refer to Item 1603(a)(3) of Regulation S-K.

 Response : The Company acknowledges
the comments of the Staff and respectfully advises the Staff that the SPAC sponsor, its affiliates and its promoters do not have experience
organizing special purpose acquisition companies that would require disclosure under Item 1603(a)(3) of Regulation S-K.

 Our Sponsor, page 3

 3. We note your statements that, other than Mr. Kamfar, no other person has a direct or indirect material interest in your sponsor
and that other than your management team, "none of the other members of your sponsor" will participate in your company's
activities. Please clarify if there are multiple members of your sponsor and, if so, why Mr. Kamfar is the only person with a material
interest in your sponsor. Additionally, please disclose, as of the most recent practicable date, all persons who have direct and indirect
material interests in the SPAC sponsor, as well as the nature and amount of their interests. Please refer to Item 1603(a)(7) of Regulation
S-K.

 Response : The Company acknowledges
the comments of the Staff and has revised the disclosure on pages 3 and 111.

 Founder Shares, page 19

 4. We note your disclosure that up to 1,000,000 of the founder shares will be surrendered for no consideration "depending on
the extent to which the underwriter's overallotment option is not exercised." Please provide more detail describing the circumstances
under which founder shares will be surrendered, including how the amount will be determined if only a portion of the over-allotment option
is exercised.

 Response : The Company acknowledges
the comments of the Staff and has revised the disclosure on page 20.

 Risk Factors

 Risks Relating to our Sponsor and Management
Team

 Members of our management team and affiliated
companies may have been..., page 77

 5. We note that members of your management and affiliated companies "may have been" involved in civil disputes or governmental
investigations unrelated to your business and such civil disputes or governmental investigations could be detrimental to your reputation,
negatively affect your ability to identify and complete an initial business combination and may have an adverse effect on the price of
your securities. Once all members of your management team are identified, please revise to disclose if you are aware of any such civil
disputes or government investigations, to the extent material.

 Response : The Company acknowledges
the comments of the Staff and has revised the disclosure on page 79.

 2

 United States Securities and Exchange Commission

 November 6, 2025

 Risks Relating to our Securities

 Our warrant agreement will designate the courts
of the State of New York..., page 86

 6. Please expand your risk factor to note that the exclusive forum provisions in the warrant agreement may also increase a warrant
holder's cost to bring a claim.

 Response : The Company acknowledges
the comments of the Staff and has revised the disclosure on page 87.

 Dilution, page 100

 7. Outside of your Dilution table, please describe each material potential source of future dilution following the registered offering
by the special purpose acquisition company, including sources not included in the table with respect to the determination of net tangible
book value per share, as adjusted. These sources of dilution should include the founder shares anti-dilution rights, shares that may be
issued in connection with the closing of your initial business combination, private warrants, public warrants and potential conversion
of any working capital loans. Please refer to Item 1602(c) of Regulation S-K.

 Response : The Company acknowledges
the comments of the Staff and has revised the disclosure on page 100.

 * * *

 3

 United States Securities and Exchange Commission

 November 6, 2025

 Please do not hesitate to
contact Elliott Smith at (212) 261-6847 of Perkins Coie LLP with any questions or comments regarding this letter.

 Best regards,

 /s/ Perkins Coie LLP

 cc:
 R. Ramin Kamfar, Chief Executive Officer and Chairman

 4

September 24, 2025
R. Ramin Kamfar
Chief Executive Officer and Chairman
Bluerock Acquisition Corp.
919 Third Avenue
New York, New York 10022
Re:Bluerock Acquisition Corp.
Draft Registration Statement on Form S-1
Submitted August 29, 2025
CIK No. 0002081532
Dear R. Ramin Kamfar:
            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 August 29, 2025
Summary, page 1
1.Please revise your summary to disclose, as you do in your risk factors, that significant
competition may impact the attractiveness of the acquisition terms that the SPAC will
be able to negotiate with a potential target company.
Our Company, page 3
We note your statement that your directors and officers, or their respective affiliates,
"may in the future" become affiliated with other SPACs that may have acquisition
objectives that are similar to yours. Please expand on this disclosure to more explicitly
describe the experience of the SPAC sponsor, its affiliates, and any promoters in
organizing special purpose acquisition companies and the extent to which the SPAC 2.

September 24, 2025
Page 2
sponsor, its affiliates, and the promoters are involved in other special purpose
acquisition companies. Please refer to Item 1603(a)(3) of Regulation S-K.
Our Sponsor, page 3
3.We note your statements that, other than Mr. Kamfar, no other person has a direct or
indirect material interest in your sponsor and that other than your management team,
"none of the other members of your sponsor" will participate in your company’s
activities. Please clarify if there are multiple members of your sponsor and, if so, why
Mr. Kamfar is the only person with a material interest in your sponsor. Additionally,
please disclose, as of the most recent practicable date, all persons who have direct and
indirect material interests in the SPAC sponsor, as well as the nature and amount of
their interests. Please refer to Item 1603(a)(7) of Regulation S-K.
Founder Shares, page 19
4.We note your disclosure that up to 1,000,000 of the founder shares will be surrendered
for no consideration "depending on the extent to which the underwriter's over-
allotment option is not exercised." Please provide more detail describing the
circumstances under which founder shares will be surrendered, including how the
amount will be determined if only a portion of the over-allotment option is exercised.
Risk Factors
Risks Relating to our Sponsor and Management Team
Members of our management team and affiliated companies may have been..., page 77
5.We note that members of your management and affiliated companies "may have
been" involved in civil disputes or governmental investigations unrelated to your
business and such civil disputes or governmental investigations could be detrimental
to your reputation, negatively affect your ability to identify and complete an initial
business combination and may have an adverse effect on the price of your securities.
Once all members of your management team are identified, please revise to disclose if
you are aware of any such civil disputes or government investigations, to the extent
material.
Risks Relating to our Securities
Our warrant agreement will designate the courts of the State of New York..., page 86
6.Please expand your risk factor to note that the exclusive forum provisions in the
warrant agreement may also increase a warrant holder’s cost to bring a claim.
Dilution, page 100
7.Outside of your Dilution table, please describe each material potential source of future
dilution following the registered offering by the special purpose acquisition company,
including sources not included in the table with respect to the determination of net
tangible book value per share, as adjusted. These sources of dilution should include
the founder shares anti-dilution rights, shares that may be issued in connection with
the closing of your initial business combination, private warrants, public warrants and
potential conversion of any working capital loans. Please refer to Item 1602(c) of
Regulation S-K.

September 24, 2025
Page 3
            Please contact Tayyaba Shafique at 202-551-2110 or Michael Fay at 202-551-3812 if
you have questions regarding comments on the financial statements and related
matters. Please contact Katherine Bagley at 202-551-2545 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Elliott M. Smith, Esq.