SecProbe.io

CORRESP
 1
 filename1.htm

 Paloma Acquisition Corp I

 535 Fifth Avenue, 4th Floor

 New York, NY 10017

 February 17, 2026

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street,
NE

 Washington, D.C. 20549

 Attention: Ruairi Regan

 RE: 
 Paloma Acquisition Corp I (the "Company")

  
 Registration Statement on Form S-1

 ( File No. 333-293083) (the "Registration Statement" )

 Ladies and Gentlemen:

 Reference
is made to our letter, filed as correspondence via EDGAR on February 13, 2026, in which we requested the acceleration of the effective
time of the above-referenced Registration Statement for 4:00 p.m., Eastern Time, on February 17, 2026, in accordance with Rule 461 promulgated
under the Securities Act of 1933, as amended. We are no longer requesting that such Registration Statement be declared effective at this
time and we hereby formally withdraw our request for acceleration of the effective time. Thank you for your assistance in this matter.

 Please
contact Anthony Zangrillo, of Greenberg Traurig, LLP, counsel to the Company, at (212) 801-9213, if you have any other questions or concerns
regarding this matter.

 [Signature page follows]

 Very
 truly yours,

 PALOMA
 ACQUISITION CORP I

 By:
 /s/ Anna Nahajki-Staples

 Name:
 Anna Nahajki-Staples

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 Jefferies LLC

 520 Madison Avenue

 New York, New York 10022

 February 17, 2026

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn.: Ruairi Regan

 Re:
 Paloma Acquisition Corp I

 Registration Statement on Form S-1

 Filed January 30, 2026, as amended

 File No. 333-293083

 Dear Ladies and Gentlemen:

 On February 13, 2026, the undersigned, as the
representative of the several underwriters, joined in the request of Paloma Acquisition Corp I 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 February 17, 2026, or as soon
thereafter as practicable, pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended. Paloma
Acquisition Corp I is no longer requesting that such Registration Statement be declared effective at this time, and we hereby respectfully
withdraw our acceleration request dated February 13, 2026.

 * * *

 [ Signature Page Follows ]

 Very truly yours,

 JEFFERIES LLC

 By :
 /s/ Tina Pappas

 Name:
 Tina Pappas

 Title:
 Managing Director

 [ Signature Page to Underwriters'
Withdrawal of Acceleration Request ]

CORRESP
 1
 filename1.htm

 Paloma Acquisition Corp I

 535 Fifth Avenue, 4th Floor

 New York, NY 10017

 February 17, 2026

 VIA EDGAR
United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Attention: Ruairi Regan

 RE: Paloma Acquisition Corp I (the "Company")

 Registration Statement on Form S-1 

 ( File No. 333-293083) (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 4:00 p.m. on February 18, 2026, or as soon thereafter
as practicable.

 [Signature page follows]

 Very truly yours,

 PALOMA ACQUISITION CORP I

 By:
 /s/ Anna Nahajki-Staples

 Name:
 Anna Nahajski-Staples

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 Jefferies LLC

 520 Madison Avenue

 New York, New York 10022

 February 17, 2026

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn.: Ruairi Regan

 Re:
 Paloma Acquisition Corp I

 Registration Statement on Form S-1

 Filed January 30, 2026, as amended

 File No. 333-293083

 Dear Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended (the "Act"), the undersigned, for themselves and the other several
underwriters, hereby joins in the request of Paloma Acquisition Corp I that the effective date of the above-referenced Registration Statement
be accelerated so as to permit it to become effective at 4:00 pm Eastern time on February 18, 2026, or as soon thereafter as practicable.

 Pursuant to Rule 460 of the General Rules and
Regulations under the Act, the undersigned advises that approximately 300 copies of the Preliminary Prospectus dated February 17,
2026 are expected to be distributed to prospective underwriters and dealers, institutional investors, retail investors and others.

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

 * * *

 [ Signature Page Follows ]

 Very truly yours,

 jefferies
 llc

 By:
 /s/ Tina Pappas

 Name:
 Tina Pappas

 Title:
 Managing Director

 [ Signature Page to Underwriters'
Acceleration Request Letter ]

CORRESP
 1
 filename1.htm

 Paloma Acquisition Corp I

 535 Fifth Avenue, 4th Floor

 New York, NY 10017

 February 13, 2026

 VIA EDGAR
United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Attention: Ruairi Regan

 RE: Paloma Acquisition Corp I (the "Company")

 Registration Statement on Form S-1 

 ( File No. 333-293083) (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 4:00 p.m. on February 17, 2026, or as soon thereafter
as practicable.

 [Signature page follows]

 Very truly yours,

 PALOMA ACQUISITION CORP I

 By:
 /s/ Anna Nahajki-Staples

 Name:
 Anna Nahajski-Staples

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 Jefferies LLC
 520 Madison Avenue
 New York, New York 10022

 February 13, 2026

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn.: Ruairi Regan

 Re: Paloma Acquisition Corp I Registration
Statement on Form S-1

 Filed January 30, 2026,
as amended

 File No. 333-293083

 Dear Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended (the "Act"), the undersigned, for themselves and the other several
underwriters, hereby joins in the request of Paloma Acquisition Corp I that the effective date of the above-referenced Registration Statement
be accelerated so as to permit it to become effective at 4:00 pm Eastern time on February 17, 2026, or as soon thereafter as practicable.

 Pursuant to Rule 460 of the General Rules and
Regulations under the Act, the undersigned advises that approximately 300 copies of the Preliminary Prospectus dated February 11,
2026 are expected to be distributed to prospective underwriters and dealers, institutional investors, retail investors and others.

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

 * * *

 [ Signature Page Follows ]

 Very truly yours,

 jefferies
 llc

 By:
 /s/ Tina Pappas

 Name:
 Tina Pappas

 Title:
 Managing Director

 [ Signature Page to Underwriters'
Acceleration Request Letter ]

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 26, 2026

Anna Nahajski-Staples
Chief Executive Officer
Paloma Acquisition Corp I
535 Fifth Avenue, 4th Floor
New York, New York 10017

 Re: Paloma Acquisition Corp I
 Draft Registration Statement on Form S-1
 Submitted December 23, 2025
 CIK No. 0002101562
Dear Anna Nahajski-Staples:

 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 Ruairi Regan at 202-551-3269 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Anthony J. Zangrillo, Esq.
</TEXT>
</DOCUMENT>