SecProbe.io

CORRESP
 1
 filename1.htm

 BEST SPAC I Acquisition Corp.

 701, 7/Floor

 United Building

 17-19 Jubilee Street

 Hong Kong

 June 10, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, N.E.

 Washington, D.C. 20549

 RE:
 BEST SPAC I Acquisition Corp. (the "Company")

 Registration Statement on Form S-1

 (File No. 333-286237) (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 4:30 p.m., Eastern time, on June 12, 2025, or as soon thereafter as practicable.

 The Company hereby acknowledges
that:

 ●
 Should the Securities and Exchange Commission (the "Commission") or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

 ●
 The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

 ●
 The Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 If there is any change in
the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making
an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461 of Regulation C. Such
request may be made by an executive officer of the Company or by any attorney from the Company's U.S. counsel, Loeb & Loeb LLP.

 [ Signature page follows ]

 Very truly yours,

 BEST SPAC I Acquisition Corp.

 By:
 /s/ Xiangge Liu

 Name:
 Xiangge Liu

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 June 10, 2025

 VIA EDGAR

 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: Isabel Rivera

 Re: BEST SPAC I Acquisition Corp.

 Registration Statement on Form S-1, as amended (File
No. 333-286237)

 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 As the representative of the
underwriters of the proposed initial public offering of BEST SPAC I Acquisition Corp. (the "Company"), we hereby join the
Company's request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 4:30 pm Eastern
Time, on June 12, 2025, or as soon thereafter as is practicable.

 Pursuant to Rule 460 of the
General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, we wish to
advise you that, through June 12, 2025, we distributed to each dealer, institutional investor, or retail investor, who is reasonably anticipated
to be invited to participate in the distribution of the security, as many copies, as well as "E-red" copies of the Preliminary
Prospectus dated May 23, 2025, as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

 The undersigned advise that
they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 Very truly yours

 Maxim Group LLC

 By:
 /s/ Larry Glassberg

 Name:
 Larry Glassberg

 Title:

 Co-Head of Investment Banking,
 Executive Managing Director

CORRESP
 1
 filename1.htm

 Giovanni Caruso

 Partner

 345 Park Avenue
 Direct
 212.407.4866

 New York, NY 10154
 Main
 212.407.4000

 Fax
 212.937.3943

 gcaruso@loeb.com

 May 23, 2025

 Ameen Hamady
Kristina Marrone
Isabel Rivera
Benjamin Holt

 Division of Corporation Finance

 U.S. Securities & Exchange Commission

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Re:
 BEST SPAC I Acquisition Corp.
Registration Statement on Form S-1
Filed March 28, 2025
File No. 333-286237

 Ladies and Gentlemen:

 On behalf of our client, BEST
SPAC I Acquisition Corp. (the "Company"), we hereby provide a response to the comments issued in a letter dated April 10,
2025 (the "Staff's Letter") regarding the above-referenced Registration Statement on Form S-1 (the "Registration
Statement"). Contemporaneously, the Company is filing a revised Registration Statement via EDGAR (the "Amended Registration
Statement"), which reflects the Company's responses to the comments received by the Staff and certain updated information.

 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 comment set forth in the Staff's Letter. 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 filed March 28,
2025

 Note 2 - Basis of Presentation and Summary
of Significant Accounting Policies Recent Accounting Pronouncements, page F-12

 1.
 We note your disclosure that Company's management does not believe that the adoption of ASU 2023-07 will have a material impact on the audited financial statements and disclosures. Please tell us how the Company considered the additional reportable segment disclosure requirements of ASU 2023-07. Please advise or revise accordingly.

 Response: In response to the
Staff's comment, the Company has revised the disclosure on pages F-33-34 of the Amended Registration Statement.

 U.S. Securities and Exchange Commission
 May 23, 2025
 Page 2

 Please call me at (212) 407-4866
if you would like additional information with respect to any of the foregoing. Thank you.

 /s/ Giovanni Caruso

 Giovanni Caruso

 Partner

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 10, 2025

Xiangge Liu
Chairman, Chief Executive Officer and Chief Financial Officer
BEST SPAC I Acquistion Corp.
701, 7/Floor
United Building
17-19 Jubilee Street
Hong Kong

 Re: BEST SPAC I Acquistion Corp.
 Registration Statement on Form S-1
 Filed March 28, 2025
 File No. 333-286237
Dear Xiangge Liu:

 We have reviewed your registration statement and have the following
comment.

 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 March 28, 2025
Note 2 - Basis of Presentation and Summary of Significant Accounting Policies
Recent Accounting Pronouncements, page F-12

1. We note your disclosure that Company's management does not believe that
the
 adoption of ASU 2023-07 will have a material impact on the audited
financial
 statements and disclosures. Please tell us how the Company considered
the additional
 reportable segment disclosure requirements of ASU 2023-07. Please advise
or revise
 accordingly.
 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.
 April 10, 2025
Page 2

 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 Ameen Hamady at 202-551-3891 or Kristina Marrone at
202-551-3429
if you have questions regarding comments on the financial statements and
related
matters. Please contact Isabel Rivera at 202-551-3518 or Benjamin Holt at
202-551-6614
with any other questions.

 Sincerely,

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

CORRESP
 1
 filename1.htm

 Giovanni Caruso

 Partner

 345 Park Avenue
 Direct
 212.407.4866

 New York, NY 10154
 Main
 212.407.4000

 Fax
 212.937.3943

 gcaruso@loeb.com

 March 28, 2025

 Ameen Hamady
Kristina Marrone
Isabel Rivera
Benjamin Holt

 Division of Corporation Finance

 U.S. Securities & Exchange Commission

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Re:
 BEST SPAC I Acquisition Corp.
Draft Registration Statement on Form S-1
Submitted January 10, 2025
CIK No. 0002051587

 Ladies and Gentlemen:

 On behalf of our client, BEST
SPAC I Acquisition Corp. (the "Company"), we hereby provide a response to the comments issued in a letter dated February 6,
2025 (the "Staff's Letter") regarding the above-referenced Draft Registration Statement on Form S-1 (the "Registration
Statement"). Contemporaneously, the Company is filing a revised Registration Statement via EDGAR (the "Amended Registration
Statement"), which reflects the Company's responses to the comments received by the Staff and certain updated information.

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

 Draft Registration Statement on Form S-1 submitted January 10,
2025

 Cover Page

 1.
 We note that you checked the Rule 415 box on the cover page, but your disclosure elsewhere indicates that this is a firm commitment, underwritten offering. Please advise or revise accordingly.

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

 Los Angeles       New York       Chicago     
Nashville      Washington, DC      San Francisco      Beijing
     Hong Kong      www.loeb.com

 For the United States offices, a limited
liability partnership including professional corporations. For Hong Kong office, a limited liability partnership.

 U.S. Securities and Exchange Commission

 March 28,
2025

 Page 2

 2. We note your disclosure regarding compensation and securities issuance. Please expand your disclosure
to state whether the conversion of the working capital loans into private placement units may result in a material dilution of the purchasers'
equity interests. Refer to Item 1602(a)(3) of Regulation S-K.

 Response: In response to the
Staff's comment, the Company has revised the disclosure on the cover page and pages 3, 6 and 133 of the Amended Registration
Statement.

 3. Please reconcile your statement here and on page 15 of your prospectus that your officers and directors
will maintain their fiduciary duty and that you will retain priority over any subsequent SPACs or ventures they may join with your disclosure
on page 18 and elsewhere throughout your prospectus that you have renounced your interest or expectancy in any corporate opportunity offered
to an officer or director which is suitable to another entity to which they owe fiduciary or contractual obligations unless the opportunity
is presented to such officer and director in their capacity as an officer or director of your company.

 Response: In response to the
Staff's comment, the Company has revised the disclosure on the cover page and pages 11, 17, 135 and 158-159 of the Amended Registration
Statement.

 Prospectus
Summary

 Leadership
of an Experienced Management and Director Team, page 4

 4. Please revise your disclosure here, under "Other Acquisition Considerations" on page 14,
under "Potential Conflicts" on page 18, and elsewhere as appropriate to reference all positions currently held by your management
team. Also revise to reconcile your statement on pages 15, 18, and 130, "None of our other officers or directors has any previous
or current experience with a special purpose acquisition company." In this regard, we note that your management team simultaneously
maintains positions with BEST SPAC II Acquisition Corp.

 Response: In response to
the Staff's comment, the Company has revised the disclosure on pages 4-5, 11, 16, 20, 57, 127-128, 132, 161-162, 167 and
169-170 of the Amended Registration Statement.

 Compensation, page 5

 5. Please revise your disclosure outside the table on pages 5-6 to describe the extent to which this compensation
and securities issuance may result in a material dilution of the purchasers' equity interests, including the conversion of the working
capital loans into private placement units. Refer to Item 1602(b)(6) of Regulation S-K.

 Response: In response to the
Staff's comment, the Company has revised the disclosure on the cover page and pages 3, 6 and 133 of the Amended Registration
Statement.

 Legal and Operational Risks Associated with
being based in China, page 10

 6. Please expand to disclose the basis for your belief that for this offering you are not subject to registration
with the CSRC pursuant to the Trial Measures, as you state on page 89.

 Response: In response to the
Staff's comment, the Company has revised the disclosure on page 13 of the Amended Registration Statement.

 U.S. Securities and Exchange Commission

 March 28,
2025

 Page 3

 Private placement units, page 28

 7. We note your statement here and elsewhere throughout your prospectus that your private placement units
are identical to the units sold in this offering "except as described in this prospectus." Other than the transfer restrictions
on the private placement units, please describe or provide a cross-reference to disclosure elsewhere that describes, how the private placement
units, including the component securities, are not identical to the units sold in this offering.

 Response: In response to the
Staff's comment, the Company has revised the disclosure on the cover page and pages 30, 76, 125, 133, 173, 175 and 182 of the Amended
Registration Statement.

 Risk Factors
Risks Relating to our Sponsor, Management and Director Team
The ownership interest of our sponsor may change, and our sponsor may divest its ownership interest in us before identifying . . ., page
68

 8. Please revise your risk factor disclosure to state the risk, if applicable, that any replacement sponsor
could have difficulty finding a target.

 Response: In response to the
Staff's comment, the Company has revised the disclosure on pages 70-71 of the Amended Registration Statement.

 Risks Associated with Acquiring and Operating a Business with
its Primary Operation in China
Other PRC governmental authorities may take the view now or in the future that an approval from them is required for an overseas . . .,
page 87

 9. Please revise your risk factor disclosure to specifically address the impact that PRC law or regulation
may have on the cash flows associated with the business combination, including shareholder redemption rights.

 Response: In response to the
Staff's comment, the Company has revised the disclosure on page 92 of the Amended Registration Statement.

 General

 10. Please disclose the material terms of any agreement regarding transfer restrictions on your securities
in a tabular format to the extent practicable, as required by Item 1603(a)(9) of Regulation S-K.

 Response: In response to the
Staff's comment, the Company has revised the disclosure on pages 7-8 and 135-137 of the Amended Registration Statement.

 Please call me at (212) 407-4866
if you would like additional information with respect to any of the foregoing. Thank you.

 /s/ Giovanni Caruso

 Giovanni Caruso

 Partner

February 6, 2025
Xiangge Liu
Chairman, Chief Executive Officer and Chief Financial Officer
BEST SPAC I Acquistion Corp.
701, 7/Floor
United Building
17-19 Jubilee Street
Hong Kong
Re:BEST SPAC I Acquistion Corp.
Draft Registration Statement on Form S-1
Submitted January 10, 2025
CIK No. 0002051587
Dear Xiangge Liu:
            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 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 January 10, 2025
Cover Page
1.We note that you checked the Rule 415 box on the cover page, but your disclosure
elsewhere indicates that this is a firm commitment, underwritten offering. Please
advise or revise accordingly.
2.We note your disclosure regarding compensation and securities issuance. Please
expand your disclosure to state whether the conversion of the working capital loans
into private placement units may result in a material dilution of the purchasers' equity
interests. Refer to Item 1602(a)(3) of Regulation S-K.

February 6, 2025
Page 2
3.Please reconcile your statement here and on page 15 of your prospectus that your
officers and directors will maintain their fiduciary duty and that you will retain
priority over any subsequent SPACs or ventures they may join with your disclosure
on page 18 and elsewhere throughout your prospectus that you have renounced your
interest or expectancy in any corporate opportunity offered to an officer or director
which is suitable to another entity to which they owe fiduciary or contractual
obligations unless the opportunity is presented to such officer and director in their
capacity as an officer or director of your company.
Prospectus Summary
Leadership of an Experienced Management and Director Team, page 4
4.Please revise your disclosure here, under "Other Acquisition Considerations" on page
14, under "Potential Conflicts" on page 18, and elsewhere as appropriate to
reference all positions currently held by your management team. Also revise to
reconcile your statement on pages 15, 18, and 130, "None of our other officers or
directors has any previous or current experience with a special purpose acquisition
company." In this regard, we note that your management team simultaneously
maintains positions with BEST SPAC II Acquisition Corp.
Compensation, page 5
5.Please revise your disclosure outside the table on pages 5-6 to describe the extent to
which this compensation and securities issuance may result in a material dilution of
the purchasers' equity interests, including the conversion of the working capital loans
into private placement units. Refer to Item 1602(b)(6) of Regulation S-K.
Legal and Operational Risks Associated with being based in China, page 10
6.Please expand to disclose the basis for your belief that for this offering you are not
subject to registration with the CSRC pursuant to the Trial Measures, as you state on
page 89.
Private placement units, page 28
7.We note your statement here and elsewhere throughout your prospectus that your
private placement units are identical to the units sold in this offering "except as
described in this prospectus." Other than the transfer restrictions on the private
placement units, please describe or provide a cross-reference to disclosure elsewhere
that describes, how the private placement units, including the component
securities, are not identical to the units sold in this offering.
Risk Factors
Risks Relating to our Sponsor, Management and Director Team
The ownership interest of our sponsor may change, and our sponsor may divest its ownership
interest in us before identifying . . ., page 68
8.Please revise your risk factor disclosure to state the risk, if applicable, that any
replacement sponsor could have difficulty finding a target.

February 6, 2025
Page 3
Risks Associated with Acquiring and Operating a Business with its Primary Operation in
China
Other PRC governmental authorities may take the view now or in the future that an approval
from them is required for an overseas . . ., page 87
9.Please revise your risk factor disclosure to specifically address the impact that PRC
law or regulation may have on the cash flows associated with the business
combination, including shareholder redemption rights.
General
10.Please disclose the material terms of any agreement regarding transfer restrictions on
your securities in a tabular format to the extent practicable, as required by Item
1603(a)(9) of Regulation S-K.
            Please contact Ameen Hamady at 202-551-3891 or Kristina Marrone at 202-551-3429
if you have questions regarding comments on the financial statements and related
matters. Please contact Isabel Rivera at 202-551-3518 or Benjamin Holt at 202-551-6614
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Giovanni Caruso