SecProbe.io

CORRESP
 1
 filename1.htm

 Via
EDGAR Submission

 October
31, 2025

 Office
of Finance

 Division
of Corporation Finance

 U.S.
Securities and Exchange Commission

 100
F Street, NE

 Washington,
D.C. 20549

 Howard
Efron

 Isaac
Esquivel

 Ruairi
Regan

 Jeffrey
Gabor

 Re:
New America Acquisition I Corp.

 Amendment
No. 1 to Registration Statement on Form S-1 Filed August 4, 2025

 CIK
No. 0002074878

 Dear
Howard Efron, Isaac Esquivel, Ruairi Regan and Jeffrey Gabor:

 On
behalf of New America Acquisition I Corp., a Florida corporation and blank check company (" we " or the " Registrant "),
we submit to the staff (the " Staff ") of the Securities and Exchange Commission (the " Commission ")
this letter setting forth the Registrant's responses to the comments contained in the Staff's letter dated August 31, 2025,
regarding the Registrant's Amendment No. 1 to the Registration Statement on Form S-1 filed with the Commission on August 4, 2025
(" Amendment No. 1 "). For the Staff's convenience, we have repeated below each of the Staff's comments
in bold and have followed such comment with the Registrant's response. Concurrently with the transmission of this letter, we are
filing the Registrant's Amendment No. 2 to the Registration Statement on Form S-1 with the Commission through EDGAR (" Amendment
No. 2 "), which reflects the Registrant's responses to the comments received by the Staff and certain updated information.
All page references in the responses set forth below refer to page numbers in Amendment No. 2.

 Amendment
No. 2 to the Re g istration Statement on Form S-1 filed October 31, 2025

 Sponsor
Information, pages 11 and 101

 1. Please
 revise to clarify, as of the most recent practicable date, the persons who have direct and
 indirect material interests in the SPAC sponsor, as well as the nature and amount of their
 interests. See Item 1603(a)(7) of Regulation S-K.

 Response :
The Registrant acknowledges the Staff's comment and has revised Amendment No. 2 on pages 11 and 102 in response to
the Staff's comment.

 2. With
 a view toward disclosure, please tell us whether your sponsor is controlled by, has any members
 who are, or has substantial ties with, a non-U.S. person.

 Response :
We supplementally advise the Staff that New America Sponsor I LLC, the Registrant's sponsor (the " Sponsor "), a Florida limited liability company, is controlled by the Registrant's Chief Executive Officer and Chairman, Kevin McGurn,
who is a U.S. citizen. Further, the Sponsor does not have any substantial ties to a non-U.S person.

 Prior
SPAC Experience, pages 6 and 106

 3. Please
 revise to clarify the experience of the sponsor, its affiliates, and any promoters in organizing
 or involvement in special purpose acquisition companies. Please revise to disclose the name
 of the SPAC, the ticker symbol, any SPAC liquidations, and information concerning any completed
 business combinations, including the financing needed for the transactions and the level
 of redemptions. Also, disclose any extensions and redemption levels in connection with an
 extension and/or business combination. See Item 1603(a)(3) of Regulation S-K.

 Response :
The Registrant respectfully acknowledges the Staff's comment. We direct the Staff to the disclosures under the headings "Prior
SPAC Experience" on pages 6 and 106 discussing: Mr. McGurn and Mr. McDonagh's involvement in the initial
public offering of Yorkville Acquisition Corp., a special purpose acquisition company, and its subsequent entry into a business combination
agreement; and Ms. Ingargiola's involvement in the initial public offering of D. Boral ARC Acquisition I Corp., a special purpose
acquisition company, and her prior SPAC experience.

 *
* * *

 If
you have any questions regarding this submission, please contact Gil Savir at 212-318-6080.

 Thank
you for your time and attention.

 Sincerely,

 /s/ Gil Savir

 Gil Savir

 of PAUL HASTINGS LLP

August 31, 2025
Kevin McGurn
Chief Executive Officer and Chairman of the Board
New America Acquisition I Corp.
590 Madison Avenue, 39th Floor
New York, NY 10022
Re:New America Acquisition I Corp.
Amendment No. 1 to Registration Statement on Form S-1
Filed August 4, 2025
File No. 333-289204
Dear Kevin McGurn:
            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.
Amendment No. 1 to Registration Statement on Form S-1
Sponsor Information, page 101
1.Please revise to clarify, as of the most recent practicable date, the persons who have
direct and indirect material interests in the SPAC sponsor, as well as the nature and
amount of their interests. See Item 1603(a)(7) of Regulation S-K
2.With a view toward disclosure, please tell us whether your sponsor is controlled by,
has any members who are, or has substantial ties with, a non-U.S. person.
Prior SPAC Experience, page 106
Please revise to clarify the experience of the sponsor, its affiliates, and any promoters
in organizing or involvement in special purpose acquisition companies. Please revise
to disclose the name of the SPAC, the ticker symbol, any SPAC liquidations, and
information concerning any completed business combinations, including the financing 3.

August 31, 2025
Page 2
needed for the transactions and the level of redemptions. Also, disclose any extensions
and redemption levels in connection with an extension and/or business combination.
See Item 1603(a)(3) of Regulation S-K.
            Please contact Howard Efron at 202-551-3439 or Isaac Esquivel at 202-551-3395 if
you have questions regarding comments on the financial statements and related
matters. Please contact Ruairi Regan at 202-551-3269 or Jeffrey Gabor at 202-551-2544 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Gil Savir, Esq.