SecProbe.io

CORRESP
 1
 filename1.htm

 D.
Boral Capital LLC

 590
Madison Avenue, 39th Floor

 New
York, New York 10022

 September
29, 2025

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Real Estate & Construction

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attn:
Mary Beth Breslin, Catherine

 De
Lorenzo and Pamela Howell

 Re:
 BM Acquisition Corp.

 Registration Statement on Form S-1, as
 amended

 File No. 333-288106

 Acceleration
Request

 Requested
Date: September 30, 2025

 Requested
Time:4:00 p.m., Eastern Time

 Ladies
and Gentlemen:

 In
accordance with Rule 461 under the Securities Act of 1933, as amended (the " Act "), D. Boral Capital LLC, as
representative of the several underwriters, hereby joins BM Acquisition Corp. in requesting that the Securities and Exchange Commission
take appropriate action to cause the Registration Statement on Form S-1 (File No. 333-288106) (the " Registration Statement ")
to become effective on September 30, 2025, at 4:00 p.m., Eastern time, or as soon as practicable thereafter.

 Pursuant
to Rule 460 under the Act, please be advised that we will take reasonable steps to secure adequate distribution of the preliminary prospectus,
to underwriters, dealers, institutions and others, prior to the requested effective time of the Registration Statement.

 The
undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended, in connection with the above referenced proposed offering.

 [ Signature
Page Follows ]

 Very truly yours,

 D. BORAL CAPITAL LLC

 By:
 /s/ Gaurav Verma

 Name:
 Gaurav Verma

 Title:
 Co-Head Investment Banking

 cc:
 Traviss Loong Kam Seng (BM
 Acquisition Corp.)

 Debbie A. Klis, Esq. (Rimon,
 P.C.)

 Jeffrey Selman, Esq. (DLA Piper LLP (US))

 Elena Nrtina, Esq. (DLA Piper
 LLP (US))

 [Signature Page to Acceleration Request]

CORRESP
 1
 filename1.htm

 BM
ACQUISITION CORP.

 Lot
680, Jalan Batu 1 1/2, Jalan Bangi

 43500
Semenyih Selangor, Malaysia

 September
29, 2025

 VIA
EDGAR

 U.S.
Securities & Exchange Commission

 Division
of Corporation Finance

 Office
of Real Estate & Construction

 100
F Street, NE

 Washington,
D.C. 20549

 Attn:
Mary Beth Breslin, Catherine

 De
Lorenzo and Pamela Howell

 Re:
 BM
 Acquisition Corp. (CIK No. 0002071607)

 Registration
 Statement on Form S-1

 File
 No. 333-288106

 REQUEST
 FOR ACCELERATION OF EFFECTIVENESS

 Dear
Ms. Breslin, Ms. De Lorenzo and Ms. Howell:

 I
hope this letter finds you well. BM Acquisition Corp. (the "Company") hereby requests that the effective date of the Company's
Registration Statement on Form S-1, as amended (File No. 333-288106) (the "Registration Statement"), be accelerated under
Rule 461 under the Securities Act of 1933, as amended, so that it will be declared effective at 4:00 p.m. Eastern time on Tuesday, September
30, 2025, or as soon thereafter as possible, or at such other time as the Company or its outside counsel, Rimon, P.C., request by telephone
that such Registration Statement be declared effective.

 Please
contact Debbie A. Klis of Rimon, P.C. on (202) 935-3390
 with any questions you may have regarding this request. In addition, please notify Ms. Klis by
telephone when this request for acceleration has been granted.

 Sincerely
 yours,

 By:
 /s/
 Traviss Loong Kam Seng

 Mr.
 Traviss Loong Kam Seng

 Chief
 Executive Officer

 cc:
 Rimon,
 P.C.

 Debbie
 A. Klis, Esq.

 Jeffrey
 C. Selman, Esq.

 Elena
 Nrtina, Esq.
 DLA
 Piper LLP (US)

CORRESP
 1
 filename1.htm

 1050
Connecticut Ave NW, Suite 500

 Washington,
D.C. 20036

 September
 12, 2025

 VIA
EDGAR

 Attention:
 Catherine
 De Lorenzo

 Kellie
 Kim

 Shannon
 Menjivar

 Pam
 Howell

 Division
of Corporation Finance

 Securities
and Exchange Commission

 Office
of Real Estate & Construction

 100
F Street, NE

 Washington
DC 20549

 Re:
 BM
 Acquisition Corp.

 Registration
 Statement on Form S-1

 Filed
 August 29, 2025

 File
 No. 333-288106

 Dear
Ladies and Gentlemen,

 On
behalf of BM Acquisition Corp. (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 Securities and Exchange Commission (the "Staff") dated September
9, 2025 (the "Comment Letter"), with respect to the above-referenced registration statement on Form S-1 filed on August 29,
2025 (the "Registration Statement") relating to the registration under the Securities Act of 1933, as amended, of the securities
of the Company. Concurrently with this submission, the Company has filed Amendment No. 3 to the Registration Statement (the "Amendment").

 The
responses set forth below are based upon information provided to Rimon P.C. For convenience, we have included the specific comments and
headings used in the Comment Letter in bold below. On behalf of the Company, we advise you as follows:

 Amendment
No. 2 to Form S-1 filed August 29, 2025

 Risk
Factors - Risks Associated with Our Business and Securities

 The
financial and personal interests of our sponsor, officers and directors may influence their motivation...., page 47

 1.
We note the disclosure on page 48 that the sponsor can recoup its investment in its insider shares and private shares if the combined
company's shares trade at or above $1.72 per share, or $1.54 per share if the over-allotment option is exercised in full. Please
clarify how you determined these per share amounts.

 Response :
The Company recomputed these per share amounts, as follows: (i) in the case of no exercise of the over-allotment option, the quotient
of $1.47, which is the result of the equation $2,583,290 ÷ 1,755,829 (representing (A) the sponsor's total investment
to date and (B) the total insider shares, if the underwriters' over-allotment option is not exercised, respectively); and
(ii) in the case of a full exercise of the over-allotment option, the quotient of $1.35, which is the result of the equation $2,673,290
÷ 1,980,829 (representing (A) the sponsor's total investment to date and (B) the total insider shares,
if the underwriters' over-allotment option is exercised, respectively). The Company updated the Amendment accordingly on pages
11, 48, 58, 105 and 131.

 Principal
Shareholders, page 133

 2.
Your beneficial ownership table indicates that BM Global Capital and Traviss Loong Kam Seng will own 23.5% of the outstanding class A
ordinary shares following the offering, and that insiders will own a total of 1,920,828 shares. These figures appear to be inconsistent
with the disclosure on page 8. Please confirm the accuracy of the beneficial ownership table or revise the disclosure here and elsewhere,
as appropriate.

 Response :
In response to the Staff's comment, the Company revised the beneficial ownership table on page 133. The calculation base for
page 8 and 133 is different. On page 8, under the scenario with no over-allotment, total insider share is 1,500,000 (inclusive of
an aggregate of 96,000 insider shares transferred to the Company's officers and directors and 60,000 insider shares
transferred to the advisor to the sponsor), private shares 255,829 and public shares 6,000,000, then the sponsor will
collectively own 22.6% of the ownership. On page 133, it assumes the over-allotment is not exercised and Class A ordinary shares
issued include the founder shares issued to officers and directors totaling 1,824,828 (including Class A ordinary shares to BM
Global Capital totaling 1,568,999 (after giving effect to the transfer of an aggregate of 96,000 insider shares to the
Company's officers and directors and 60,000 insider shares to the advisor to the sponsor) and 255,829 private
shares after forfeiture of 225,000 insider shares) plus 96,000 issued to officers and directors equaling 1,920,828 Class A
ordinary shares. Therefore, the beneficial ownership of BM Global Capital and Traviss Loong Kam Seng will be 1,920,828/(1,920,828 +
6,000,000) = 23.04%.

 Underwriting,
page 177

 3.
We note the revised underwriters commission table which presents total underwriting commissions of $1,200,000 assuming no exercise of
the over-allotment option, and $1,380,000 assuming full exercise. For clarity, please consider revising or supplementing this disclosure
to indicate whether these amounts reflect only the upfront underwriting commission or also include the deferred portion.

 Response :
In response to the Staff's comment, the Company revised the underwriters commission table accordingly on page 177.

 Exhibits

 4.
We note the assumption in Exhibit 5.2 that "the Warrants Agreement to be entered into in connection with the Warrants has been
duly authorized, executed and delivered by the Warrants Agent and the Company, and is a valid, binding and enforceable agreement of each
party thereto." It is not appropriate for counsel to include in its opinion assumptions that assume any of the material facts underlying
the opinion.

 Response :
In response to the Staff's comment, counsel has revised the opinion at Exhibit 5.2 accordingly.

 Refer
to Section II.B.3.a of Staff Legal Bulletin No. 19. Please remove this assumption as it relates to the Company or explain.

 General

 5.
We note the disclosure that all but one share of the class B ordinary shares were converted into class A ordinary shares. Please revise
to clarify how the anti-dilution adjustment in Section 14 of the third amended and restated memorandum and articles of association would
apply to the one remaining share outstanding. To the extent the anti-dilution adjustment applies to the remaining class B ordinary share,
please revise to clearly disclose under Items 1602(a)(3), 1602(b)(6) and 1603(a)(6) of Regulation SK.

 Response :
In response to the Staff's comment, the Company amended the letter agreement at Exhibit 10.1 whereby the insiders agree to waive
any anti-dilution adjustment with respect to the Class B ordinary shares and prepared corresponding changes throughout the Amendment
accordingly (see the cover page and pages 6, 7, 11, 14, 22, 49, 58, 101, 102, 106, 108, 131, 135, 143, and F-15.

 *****

 We
respectfully request the Staff's assistance in completing the review of the Registration Statement. If you have any additional
questions regarding any of our responses or the revised Registration Statement, please do not hesitate to contact Debbie Klis on (202)
935-3390 of Rimon P.C.

 Kindest
 regards,

 /s/
 Debbie A. Klis

 Rimon
 P.C.

 cc:
Mr. Traviss Loong Kam Seng, CEO

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 9, 2025

Traviss Loong Kam Seng
Chief Executive Officer
BM Acquisition Corp.
Lot 680, Jalan Batu 1 1/2, Jalan Bangi
43500 Semenyih Selangor, Malaysia

 Re: BM Acquisition Corp.
 Amendment No. 2 to Registration Statement on Form S-1
 Filed August 29, 2025
 File No. 333-288106
Dear Traviss Loong Kam Seng:

 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 August 1,
2025 letter.

Amendment No. 2 to Form S-1 filed August 29, 2025
Risk Factors
Risks Associated with Our Business and Securities
The financial and personal interests of our sponsor, officers and directors may
influence their
motivation...., page 47

1. We note the disclosure on page 48 that the sponsor can recoup its
investment in its
 insider shares and private shares if the combined company's shares trade
at or above
 $1.72 per share, or $1.54 per share if the over-allotment option is
exercised in full.
 Please clarify how you determined these per share amounts.
 September 9, 2025
Page 2
Principal Shareholders, page 133

2. Your beneficial ownership table indicates that BM Global Capital and
Traviss Loong
 Kam Seng will own 23.5% of the outstanding class A ordinary shares
following the
 offering, and that insiders will own a total of 1,920,828 shares. These
figures appear
 to be inconsistent with the disclosure on page 8. Please confirm the
accuracy of the
 beneficial ownership table or revise the disclosure here and elsewhere,
as appropriate.
Underwriting, page 177

3. We note the revised underwriters commission table which presents total
underwriting
 commissions of $1,200,000 assuming no exercise of the over-allotment
option, and
 $1,380,000 assuming full exercise. For clarity, please consider revising
or
 supplementing this disclosure to indicate whether these amounts reflect
only the
 upfront underwriting commission or also include the deferred portion.
Exhibits

4. We note the assumption in Exhibit 5.2 that "the Warrants Agreement to be
entered
 into in connection with the Warrants has been duly authorized, executed
and delivered
 by the Warrants Agent and the Company, and is a valid, binding and
enforceable
 agreement of each party thereto." It is not appropriate for counsel to
include in its
 opinion assumptions that assume any of the material facts underlying the
opinion.
 Refer to Section II.B.3.a of Staff Legal Bulletin No. 19. Please remove
this
 assumption as it relates to the Company or explain.
General

5. We note the disclosure that all but one share of the class B ordinary
shares were
 converted into class A ordinary shares. Please revise to clarify how the
anti-dilution
 adjustment in Section 14 of the third amended and restated memorandum
and articles
 of association would apply to the one remaining share outstanding. To
the extent the
 anti-dilution adjustment applies to the remaining class B ordinary
share, please revise
 to clearly disclose under Items 1602(a)(3), 1602(b)(6) and 1603(a)(6) of
Regulation S-
 K.

 Please contact Kellie Kim at 202-551-3129 or Shannon Menjivar at
202-551-3856 if
you have questions regarding comments on the financial statements and related
matters. Please contact Catherine De Lorenzo at 202-551-3772 or Pam Howell at
202-551-
3357 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Debbie Klis, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 1050
Connecticut Ave NW, Suite 500

 Washington,
D.C. 20036

 August
 29, 2025

 VIA
EDGAR

 Attention:
 Catherine De Lorenzo

 Kellie Kim

 Shannon Menjivar

 Pam Howell

 Division
of Corporation Finance

 Securities
and Exchange Commission

 Office
of Real Estate & Construction

 100
F Street, NE

 Washington
DC 20549

 Re:
 BM Acquisition Corp.

 Registration Statement on Form S-1

 Filed July 25, 2025

 File No. 333-288106

 Dear
Ladies and Gentlemen,

 On
behalf of BM Acquisition Corp (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 Securities and Exchange Commission (the "Staff") dated August 1,
2025 (the "Comment Letter"), with respect to the above-referenced registration statement on Form S-1 filed on July 25, 2025
(the "Registration Statement") relating to the registration under the Securities Act of 1933, as amended, of the securities
of the Company. Concurrently with this submission, the Company has filed Amendment No. 2 to the Registration Statement (the "Amendment").

 The
responses set forth below are based upon information provided to Rimon P.C. For convenience, we have included the specific comments and
headings used in the Comment Letter in bold below. On behalf of the Company, we advise you as follows:

 Form
S-1 Amendment No. 1 filed July 25, 2025

 Cover
Page

 1. We
 note the revised disclosure on the cover page and elsewhere that in connection with a business
 combination or extension of the time period to complete a business combination, public shareholders
 may redeem their shares "at a per-share price . . . equal to the aggregate amount then
 on deposit in the trust account described below, including interest (net of taxes payable
 and less interest to pay dissolution expenses up to $100,000), divided by the number of then
 issued and outstanding public shares." Please advise why you would allocate funds from
 the trust for dissolution expenses in the event of a business combination or extension and
 how such provision is consistent with Nasdaq Rule IM-5101-2(d), which says "public
 Shareholders voting against a business combination must have the right to convert their shares
 of common stock into a pro rata share of the aggregate amount then in the deposit account
 (net of taxes payable and amounts distributed to management for working capital purposes)."
 Please also reconcile such references to dissolution expenses from the interest with the
 disclosure on page 87 that you will pay the costs of liquidating the trust account from your
 remaining assets outside of the trust account.

 Response :
In response to the Staff's comment, the Company removed that language on the cover page and pages 15, 25, 28, 35, 113, 114, and
121.

 Use
of Proceeds, page 84

 2. We
 refer to footnote 5 on page 85. Please clarify the specific amount included for ARC Group
 Limited's services within the total offering expenses of $1,158,290, and consider revising
 the disclosure to clearly present this information.

 Response :
In response to the Staff's comment, the Company revised the Use of Proceeds table (page 84) and the fee table in Item 13
to specify the amount of this finance fee and has increased the amount of the Company's private placement amount accordingly
cover the increase to offering expenses.

 Underwriting,
page 177

 3. We
 refer to the per-unit commission of $0.10 and the total expense payable to the underwriters
 of $600,000, as presented in your underwriters' commissions table. Footnote (1) indicates
 that the commission payable to the underwriters is $0.10 per unit upon the consummation of
 this initial public offering, with an additional $0.10 per unit payable upon the consummation
 of an initial business combination. Additionally, your estimated offering expenses are stated
 as $986,000, which is inconsistent with the offering expenses disclosed in the Use of Proceeds
 table on page 84. Please reconcile these discrepancies or revise, as appropriate.

 Response :
In response to the Staff's comment, the Company revised the estimated offering expenses on page 178.

 *****

 We
respectfully request the Staff's assistance in completing the review of the Registration Statement. If you have any additional
questions regarding any of our responses or the revised Registration Statement, please do not hesitate to contact Debbie Klis on (202)
935-3390 of Rimon P.C.

 Kindest regards,

 /s/ Debbie
 A. Klis

 Rimon P.C.

 cc:
 Mr. Traviss Loong Kam Seng, CEO

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 1, 2025

Traviss Loong Kam Seng
Chief Executive Officer
BM Acquisition Corp.
Lot 680, Jalan Batu 1 1/2, Jalan Bangi
43500 Semenyih Selangor, Malaysia

 Re: BM Acquisition Corp.
 Amended Registration Statement on Form S-1
 Filed July 25, 2025
 File No. 333-288106
Dear Traviss Loong Kam Seng:

 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.

Form S-1 Amendment No. 1 filed July 25, 2025
Cover Page

1. We note the revised disclosure on the cover page and elsewhere that in
connection
 with a business combination or extension of the time period to complete
a business
 combination, public shareholders may redeem their shares "at a per-share
price . . .
 equal to the aggregate amount then on deposit in the trust account
described below,
 including interest (net of taxes payable and less interest to pay
dissolution expenses up
 to $100,000), divided by the number of then issued and outstanding
public shares."
 Please advise why you would allocate funds from the trust for
dissolution expenses in
 the event of a business combination or extension and how such provision
is consistent
 with Nasdaq Rule IM-5101-2(d), which says "public Shareholders voting
against a
 business combination must have the right to convert their shares of
common stock
 into a pro rata share of the aggregate amount then in the deposit
account (net of taxes
 August 1, 2025
Page 2

 payable and amounts distributed to management for working capital
purposes)."
 Please also reconcile such references to dissolution expenses from the
interest with the
 disclosure on page 87 that you will pay the costs of liquidating the
trust account from
 your remaining assets outside of the trust account.
Use of Proceeds, page 84

2. We refer to footnote 5 on page 85. Please clarify the specific amount
included for
 ARC Group Limited s services within the total offering expenses of
$1,158,290, and
 consider revising the disclosure to clearly present this information.
Underwriting, page 177

3. We refer to the per-unit commission of $0.10 and the total expense
payable to the
 underwriters of $600,000, as presented in your underwriters
commissions table.
 Footnote (1) indicates that the commission payable to the underwriters is
$0.10 per
 unit upon the consummation of this initial public offering, with an
additional $0.10
 per unit payable upon the consummation of an initial business
combination.
 Additionally, your estimated offering expenses are stated as $986,000,
which is
 inconsistent with the offering expenses disclosed in the Use of Proceeds
table on page
 84. Please reconcile these discrepancies or revise, as appropriate.
 Please contact Kellie Kim at 202-551-3129 or Shannon Menjivar at
202-551-3856 if
you have questions regarding comments on the financial statements and related
matters. Please contact Catherine De Lorenzo at 202-551-3772 or Pam Howell at
202-551-
3357 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Debbie Klis, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 1050 Connecticut Ave NW, Suite 500

 Washington, D.C. 20036

 July
 24, 2025

 VIA EDGAR

 Attention: Catherine De Lorenzo

 Kellie Kim

 Shannon Menjivar

 Pam Howell

 Division of Corporation Finance

 Securities and Exchange
Commission

 Office of Real Estate &
Construction

 100 F Street, NE

 Washington DC 20549

 Re:
 BM Acquisition Corp.

 Registration Statement on Form S-1

 Filed June 17, 2025

 File No. 333-288106

 Dear Ladies and Gentlemen,

 On behalf of BM Acquisition
Corp (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 Securities and Exchange Commission (the "Staff") dated July 14, 2025 (the "Comment Letter"),
with respect to the above-referenced registration statement on Form S-1 filed on June 17, 2025 (the "Registration Statement")
relating to the registration under the Securities Act of 1933, as amended, of the securities of the Company. Concurrently with this submission,
the Company has filed Amendment No. 1 to the Registration Statement (the "Amendment").

 The responses set forth
below are based upon information provided to Rimon P.C. For convenience, we have included the specific comments and headings used in
the Comment Letter in bold below. On behalf of the Company, we advise you as follows:

 Registration Statement on Form S-1 filed June
17, 2025

 Cover Page

 1. Where you discuss compensation, fees, reimbursements
or other cash payments paid to the sponsor, officers, directors or their respective affiliates, please revise to include cross-references
to all related disclosures. Refer to Item 1602(a)(3) of Regulation SK. 2.

 Response : The Company has revised the disclosure
on the cover page of the Amendment to clarify the compensation to be issued to the sponsor, and its affiliates, including any securities
to be issued, including cross-references highlighted by prominent type.

 2. When discussing the disparate voting rights,
please also revise to disclose that only class B ordinary shares may vote on continuing your company in a jurisdiction outside of the
Cayman Islands.

 Response : The Company has revised the disclosure
on the cover page to disclose that only class B ordinary shares may vote on continuing your company in a jurisdiction outside of the
Cayman Islands.

 Conflicts of Interest, page 10

 3. We note your disclosure on page 12 that you
are not prohibited from pursuing an initial business combination with a company that is affiliated with your sponsor, officers and directors
or their affiliates and that you are not required to obtain a fairness opinion from an independent entity. You also disclose on page
155, that in the event that you enter into a business combination with an affiliated target, you will obtain a fairness opinion from
an independent entity. Please revise your registration statement to reconcile these disclosures.

 Response : In response to the Staff's
comment, we revised the disclosure on page 12, as well as in the "Risk Factors" section of the Amendment on page 50.

 Offering proceeds to be held in trust, page 23

 4. We note your disclosure here that except for
interest earned on the funds in the trust account that may be released to you to pay your tax obligations, the proceeds held in the trust
account will not be available to you for expenses related to the offering or expenses incurred prior to a business combination. However,
you indicate on page 15 and elsewhere that an annual limit of $100,000 of interest may be released from the trust to fund your working
capital requirements. Please revise here and elsewhere to reconcile these disclosures or advise. Similarly, when discussing the liquidation
of the trust in the event you are unable to complete a business combination, please clearly disclose the $100,000 from interest to pay
dissolution expenses as set forth in Exhibit 10.2. In this regard, we note that some places, including the cover page, do not reflect
such amount to be paid from the interest on the trust.

 Response : We acknowledge the Staff's
comment and advise in response that we have revised the disclosure on the cover page and pages 15, 25, 28, 29, 30, 35, 37,
42, 43, 53, 109, 113, 114, 117, 118, 120, 121, 139, 140, 141, 154 and 155 of the Amendment to remove the language regarding
withdrawal for expenses related to the offering or expenses incurred prior to a business combination.

 Redemption rights for public shareholders upon
consummation of our initial business combination, page 28

 5. We note your disclosure here and elsewhere
in the registration statement, as well as in the Amended and Restated Memorandum and Articles of Association filed as exhibit 3.1, that
you are only required to give 10 days notice for each general meeting. Please revise here and elsewhere as applicable to be consistent
with the minimum dissemination period required by Exchange Act Rule 14a-6(q).

 Response : The Company has revised the minimum
number of days' notice for each general meeting in the Second Amended and Restated Memorandum and Articles of Association
filed Exhibit 3.1 and on pages 29, 56, 121 and 140 of the Amendment.

 Risk Factors

 Risks Associated with Our Business and Securities

 Trading in our securities may be prohibited under
the Holding Foreign Companies Accountable Act..., page 39

 6. We note your disclosure on page 40 that your
auditor is MaloneBailey, LLP, and is headquartered in Houston, Texas. You further disclose that your auditor is not headquartered in
China or Hong Kong. However, the auditor's report and consent you filed are signed by Guangdong Prouden CPAs GP, located in Guangzhou,
China. Please reconcile these discrepancies or advise.

 Response : In response to the Staff's
comment, the Company revised the disclosure on page 40 of the Amendment to correct the scrivener error by clarifying that the Company's
auditor is Guangdong Prouden CPAs GP.

 Risk Factors

 The nominal purchase price paid by our sponsor
for the insider shares may result in significant dilution...,

 page 57

 7. Please confirm the accuracy of the amounts
in this risk factor, or revise for accuracy.

 Response : We acknowledge the Staff's
comment and point the Staff to the revised computation of the implied value in the table and the notes below on page 58 of the
Amendment.

 Dilution

 Assuming No Exercise of Over-Allotment Option,
page 91

 8. We note that the amounts reflected in the "Net
proceeds from this offering and sale of the private units, net of expenses" do not represent the correct amount. Additionally,
the amounts from Public Shareholders and the Total Amount in your table at the bottom of this page do not agree with the offering. Please
revise your tables on this page to address these discrepancies, or advise. Additionally, please ensure your tabular information throughout
your filing is updated appropriately.

 Response : In response to the Staff's
comment, the Company revised the amounts reflected in the "Net proceeds from this offering and sale of the private units, net of
expenses" on page 91 and the amounts from Public Shareholders and the Total Amount in our table at the bottom of page 91 of the
Amendment and prepared conforming changes to pages 90-91 of the Amendment.

 Management Discussion and Analysis

 Liquidity and Capital Resources, page 94

 9. We note your disclosure on page 94 that the
factors discussed in this section raise substantial doubt about your ability to continue as a going concern. We also note your expert
disclosure on page 186, which states that your independent registered public accounting firm's report contains an explanatory paragraph
expressing substantial doubt about your ability to continue as a going concern, as described in Note 1 to the financial statement. We
are unable to locate this disclosure in Note 1. Please reconcile the referenced disclosures with the accountants' report on page
F-2, which does not contain such an explanatory paragraph, and with the disclosure on page F-9, which appears to indicate that the substantial
doubt about your ability to continue as a going concern has been mitigated.

 Response : We acknowledge the Staff's
comment and advise in response that the Company revised the disclosures on pages 186 and F-7 of the Amendment.

 Principal Shareholders, page 133

 10. We note you disclose here that Mr. Traviss
Loong Kam Seng is the sole member of your sponsor, and, as a result, holds voting and investment discretion with respect to the ordinary
shares held of record by the sponsor. You further disclose that all of your officers, directors and your advisors are members of the
sponsor. Please revise to clarify this discrepancy. Please also include disclosure identifying all of the controlling persons of the
sponsor, all persons with a direct or indirect material interest in the sponsor, and the nature and amount of their interests. Refer
to Item 1603(a)(7) of Regulation S-K.

 Response : The Company has revised the disclosure
on page 133 of the Amendment to clarify that Mr. Traviss Loong Kam Seng is the sole member of the sponsor.

 Exhibits

 11. Please request Cayman counsel revise its opinion
in Exhibit 5.1 to remove inappropriate assumptions or explain these assumptions. It is not appropriate for counsel to assume away material
facts underlying the opinion or any readily ascertainable facts. In this regard, for example, we note paragraphs 7,8, 9 and 11(b), (e)
and (g) of Schedule 2. Refer to Section II.B.3.a of Staff Legal Bulletin No. 19.

 Response : We acknowledge the Staff's
comment and direct the Staff to the revised Cayman counsel opinion in Exhibit 5.1 to the Amendment.

 12. We note the disclosure on page 8 that pursuant
to a letter agreement, the sponsor, officers and directors agreed "to vote all ordinary shares beneficially owned by them (whether
acquired before, in, or after this offering) in favor of our initial business combination (except that any public shares such parties
may purchase in compliance with the requirements of Rule 14e-5 under the Exchange Act would not be voted in favor of approving the business
combination transaction)." We note that the letter agreement is inconsistent with such disclosure and requires such persons to
vote all ordinary shares owned by them in favor of a business combination. Please reconcile.

 Response : We acknowledge the Staff's
comment and, in response, the Company revised the discussion of the voting obligations arising under the letter agreement on pages 9,
21, 71, and 140 of the Amendment in the form of letter agreement affixed at Exhibit 10.1.

 13. Please revise the fee table filed as Exhibit
107 to also cover the ordinary shares underlying the warrants. We note the disclosure on page 19 that you are registering the ordinary
shares underlying the warrants.

 Response : In response to the Staff's
comment, the Company revised the fee table filed attached at Exhibit 107 to also cover the ordinary shares underlying the warrants.

 *****

 We respectfully request the Staff's assistance
in completing the review of the Registration Statement. If you have any additional questions regarding any of our responses or the revised
Registration Statement, please do not hesitate to contact Debbie Klis on (202) 935-3390 of Rimon P.C.

 Kindest regards,

 /s/ Debbie A. Klis

 Rimon P.C.

 cc:
 Mr. Traviss Loong Kam Seng, CEO

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 14, 2025

Traviss Loong Kam Seng
Chief Executive Officer
BM Acquisition Corp.
Lot 680, Jalan Batu 1 1/2, Jalan Bangi
43500 Semenyih Selangor, Malaysia

 Re: BM Acquisition Corp.
 Registration Statement on Form S-1
 Filed June 17, 2025
 File No. 333-288106
Dear Traviss Loong Kam Seng:

 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 filed June 17, 2025
Cover Page

1. Where you discuss compensation, fees, reimbursements or other cash
payments paid
 to the sponsor, officers, directors or their respective affiliates,
please revise to include
 cross-references to all related disclosures. Refer to Item 1602(a)(3) of
Regulation S-
 K.
2. When discussing the disparate voting rights, please also revise to
disclose that only
 class B ordinary shares may vote on continuing your company in a
jurisdiction outside
 of the Cayman Islands.
Conflicts of Interest, page 10

3. We note your disclosure on page 12 that you not prohibited from pursuing
an initial
 business combination with a company that is affiliated with your
sponsor, officers and
 directors or their affiliates and that you are not required to obtain a
fairness opinion
 July 14, 2025
Page 2

 from an independent entity. You also disclose on page 155, that in the
event that you
 enter into a business combination with an affiliated target, you will
obtain a fairness
 opinion from an independent entity. Please revise your registration
statement to
 reconcile these disclosures.
Offering proceeds to be held in trust, page 23

4. We note your disclosure here that except for interest earned on the
funds in the trust
 account that may be released to you to pay your tax obligations, the
proceeds held in
 the trust account will not be available to you for expenses related to
the offering or
 expenses incurred prior to a business combination. However, you indicate
on page 15
 and elsewhere that an annual limit of $100,000 of interest may be
released from
 the trust to fund your working capital requirements. Please revise here
and elsewhere
 to reconcile these disclosures or advise. Similarly, when discussing the
liquidation of
 the trust in the event you are unable to complete a business
combination, please
 clearly disclose the $100,000 from interest to pay dissolution expenses
as set forth in
 Exhibit 10.2. In this regard, we note that some places, including the
cover page, do not
 reflect such amount to be paid from the interest on the trust.
Redemption rights for public shareholders upon consummation of our initial
business
combination, page 28

5. We note your disclosure here and elsewhere in the registration
statement, as well as in
 the Amended and Restated Memorandum and Articles of Association filed as
exhibit
 3.1, that you are only required to give 10 days notice for each general
meeting. Please
 revise here and elsewhere as applicable to be consistent with the
minimum
 dissemination period required by Exchange Act Rule 14a-6(q).
Risk Factors
Risks Associated with Our Business and Securities
Trading in our securities may be prohibited under the Holding Foreign Companies
Accountable Act..., page 39

6. We note your disclosure on page 40 that your auditor is MaloneBailey,
LLP, and
 is headquartered in Houston, Texas. You further disclose that your
auditor is not
 headquartered in China or Hong Kong. However, the auditor's report and
consent
 you filed are signed by Guangdong Prouden CPAs GP, located in Guangzhou,
China.
 Please reconcile these discrepancies or advise.
Risk Factors
The nominal purchase price paid by our sponsor for the insider shares may
result in
significant dilution..., page 57

7. Please confirm the accuracy of the amounts in this risk factor, or
revise for accuracy.
Dilution
Assuming No Exercise of Over-Allotment Option, page 91

8. We note that the amounts reflected in the "Net proceeds from this
offering and sale of
 the private units, net of expenses" do not represent the correct amount.
Additionally,
 the amounts from Public Shareholders and the Total Amount in your table
at the
 July 14, 2025
Page 3

 bottom of this page do not agree with the offering. Please revise your
tables on this
 page to address these discrepancies, or advise. Additionally, please
ensure your
 tabular information throughout your filing is updated appropriately.

Management Discussion and Analysis
Liquidity and Capital Resources, page 94

9. We note your disclosure on page 94 that the factors discussed in this
section raise
 substantial doubt about your ability to continue as a going concern. We
also note your
 expert disclosure on page 186, which states that your independent
registered public
 accounting firm s report contains an explanatory paragraph expressing
substantial
 doubt about your ability to continue as a going concern, as described in
Note 1 to the
 financial statement. We are unable to locate this disclosure in Note 1.
Please reconcile
 the referenced disclosures with the accountants report on page F-2,
which does not
 contain such an explanatory paragraph, and with the disclosure on page
F-9, which
 appears to indicate that the substantial doubt about your ability to
continue as a going
 concern has been mitigated.
Principal Shareholders, page 133

10. We note your disclose here that Mr. Traviss Loong Kam Seng is the sole
member of
 your sponsor, and, as a result, holds voting and investment discretion
with respect to
 the ordinary shares held of record by the sponsor. You further disclose
that all of your
 officers, directors and your advisors are members of the sponsor. Please
revise to
 clarify this discrepancy. Please also include disclosure identifying all
of the
 controlling persons of the sponsor, all persons with a direct or
indirect material
 interest in the sponsor, and the nature and amount of their interests.
Refer to Item
 1603(a)(7) of Regulation S-K.
Exhibits

11. Please request Cayman counsel revise its opinion in Exhibit 5.1 to
remove
 inappropriate assumptions or explain these assumptions. It is not
appropriate for
 counsel to assume away material facts underlying the opinion or any
readily
 ascertainable facts. In this regard, for example, we note paragraphs
7,8, 9 and 11(b),
 (e) and (g) of Schedule 2. Refer to Section II.B.3.a of Staff Legal
Bulletin No. 19.
12. We note the disclosure on page 8 that pursuant to a letter agreement,
the sponsor,
 officers and directors agreed "to vote all ordinary shares beneficially
owned by them
 (whether acquired before, in, or after this offering) in favor of our
initial business
 combination (except that any public shares such parties may purchase in
compliance
 with the requirements of Rule 14e-5 under the Exchange Act would not be
voted in
 favor of approving the business combination transaction)." We note that
the letter
 agreement is inconsistent with such disclosure and requires such persons
to vote all
 ordinary shares owned by them in favor of a business combination. Please
reconcile.
 July 14, 2025
Page 4
13. Please revise the fee table filed as Exhibit 107 to also cover the
ordinary shares
 underlying the warrants. We note the disclosure on page 19 that you are
registering
 the ordinary shares underlying the warrants.

 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 Kellie Kim at 202-551-3129 or Shannon Menjivar at
202-551-3856 if
you have questions regarding comments on the financial statements and related
matters. Please contact Catherine De Lorenzo at 202-551-3772 or Pam Howell at
202-551-
3357 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Debbie Klis, Esq.
</TEXT>
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