SecProbe.io

CORRESP
 1
 filename1.htm

 Keystone Acquisition Corp.

 142 West 57 th Street

 11 th Floor

 New York, New York 10019

 May 29, 2026

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Benjamin Holt

 Re:
 Keystone Acquisition Corp.

 Registration Statement on Form S-1

 File No. 333-295539

 Dear Mr. Holt:

 Pursuant to Rule 461 under the Securities Act
of 1933, as amended, Keystone Acquisition Corp. (the "Company") hereby requests acceleration of the effective date of the
above referenced Registration Statement to 4:00 p.m., Eastern Time, on June 2, 2026, or as soon thereafter as practicable, or at such
other time as the Company or its outside counsel, Pillsbury Winthrop Shaw Pittman LLP, requests by telephone that such Registration Statement
be declared effective.

 Please contact Stephen C.
Ashley, of Pillsbury Winthrop Shaw Pittman LLP, special counsel to the Company, at (212) 858-1101, as soon as the registration statement
has been declared effective, or if you have any other questions or concerns regarding this matter.

 Sincerely,

 /s/ Richard Chin

 Richard Chin

 Chief Executive Officer

CORRESP
 1
 filename1.htm

 May 29, 2026

 VIA EDGAR

 Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, N.E.
Washington, D.C. 20549

 Re: Keystone Acquisition Corp.
Registration Statement on Form S-1
File No. 333-295539

 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 Keystone 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 June 2, 2026, 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 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
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.

 [ signature page follows ]

 Very truly yours,

 COHEN & COMPANY CAPITAL MARKETS, A DIVISION OF COHEN & COMPANY SECURITIES, LLC

 /s/ Jerry Serowik

 Name: Jerry Serowik

 Title: Head of Cohen & Company Capital Markets

 [Signature page to Underwriter's Acceleration Request]

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 February 18, 2026

Richard Chin
Chief Executive Officer
Keystone Acquisition Corp.
142 West 57th Street
11th Floor
New York, NY 10019

 Re: Keystone Acquisition Corp.
 Draft Registration Statement on Form S-1
 Submitted January 23, 2026
 CIK No. 0002102771
Dear Richard Chin:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement and
nonpublic draft
submissions at least 15 days prior to any road show as that term is defined in
Rule 433(h)(4) or,
in the absence of a road show, at least 15 days prior to the requested
effective date of the
registration statement. Please refer to Rules 460 and 461 regarding requests
for acceleration. 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.

 Please contact Benjamin Holt at 202-551-6614 with any questions.

 Sincerely,

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