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 Acuren Corporation

 14434 Medical Complex Drive, Suite 100

 Tomball, Texas 77377

 June 25, 2025

 Securities and Exchange Commission

 Division of Corporate Finance

 100 F Street, NE

 Washington, DC 20549

 Attention:	Mr. Nico Albantiann

 Re: Acuren Corporation

 Registration Statement on Form S-4

 File No. 333-287888

 Dear Mr. Albantiann:

 Acuren Corporation (the " Company ")
hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it may become effective at 4:30
p.m. Eastern Time on June 27, 2025, or as soon as practicable thereafter, unless the Company notifies you otherwise prior to such time.

 Once the Registration Statement
has been declared effective, please contact our counsel, Flora R. Perez of Greenberg Traurig, P.A., at (954) 768-8210 to orally confirm
that event or if you have any questions or require additional information regarding this matter.

 [ Signature Page Follows ]

 Very truly yours,

 Acuren Corporation

 By:

 /s/ Fiona Sutherland

 Name:

 Fiona Sutherland

 Title:

 General Counsel and Secretary

 cc: Flora R. Perez, Esq.

 Brian J. Gavsie, Esq.

 Greenberg Traurig, P.A.

 [ Signature Page to Acceleration Request Letter ]

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 13, 2025

Talman Pizzey
President and Chief Executive Officer
Acuren Corp
14434 Medical Complex Drive
Suite 100
Tomball, TX 77377

 Re: Acuren Corp
 Registration Statement on Form S-4
 Filed June 9, 2025
 File No. 333-287888
Dear Talman Pizzey:

 This is to advise you that we have not reviewed and will not review your
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 Nicholas Nalbantian at 202-551-7470 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Alan Annex, Esq.
</TEXT>
</DOCUMENT>

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Acuren Corporation

14434 Medical Complex Drive, Suite 100

Tomball, Texas 77377

December 12, 2024

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, NE

Washington, DC 20549

 Attention: Mr. Donald Fields

 Re: Acuren Corporation

 Registration Statement on Form S-4

 File No. 333-282976

Dear Mr. Field:

Acuren Corporation (the “Company”)
hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it may become effective at 9:00
a.m. Eastern Time on December 16, 2024, or as soon as practicable thereafter, unless the Company notifies you otherwise prior to such
time.

Once the Registration Statement
has been declared effective, please contact our counsel, Flora R. Perez of Greenberg Traurig, P.A., at (954) 768-8210 to orally confirm
that event or if you have any questions or require additional information regarding this matter.

[Signature Page Follows]

    Very truly yours,

    Acuren Corporation

    By:
    /s/ Fiona Sutherland

    Name:
     Fiona Sutherland

    Title:
    General Counsel and Secretary

 cc: Flora R. Perez, Esq.

 Brian J. Gavsie, Esq.

 Greenberg Traurig, P.A.

[Signature Page to Acceleration Request Letter]

CORRESP
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December 10, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Blaise Rhodes

    Joel Parker

    Scott Anderegg

    Donald Field

    Re:
    Acuren Corporation

    Amendment No. 1 to Registration Statement on Form S-4

    Filed November 27, 2024

    File No. 333-282976

Dear Messrs. Rhodes, Parker, Anderegg and Field:

On behalf of Acuren Corporation
(the “Company”), we are responding to the comment letter of the staff (the “Staff”) of the Division of Corporation
Finance of the Securities and Exchange Commission (the “Commission,” or the “SEC”) dated December 9, 2024, relating
to the above referenced Amendment No. 1 to Registration Statement on Form S-4 (333-282976) filed by the Company on November 27, 2024 (the
“Registration Statement”).

For ease of review, we have
set forth below each of the numbered comments of your letter and the Company’s responses thereto.

Amendment No.1 to Registration Statement on
Form S-4 filed on November 27, 2024

Note 3. Business Combinations

Successor Period, page F-42

 1. You state that 400 million Acuren British Virgin Islands
Ordinary Shares were issued to ASP Acuren shareholders. It appears that 400,000 shares were issued. Please revise or advise.

Response: The Registration Statement
has been amended on page F-42 to reflect that 0.4 million shares were issued.

 2. Please tell us how the pro forma adjustments described on
page F-45 and F-46 resulted in a pro forma net loss of $7.7 million for the Successor nine months ended September 30, 2024. If applicable,
disclose any additional adjustments that you are making.

Response: The Registration Statement
has been amended on pages F-45 and F-46 as attached hereto as Annex A.

Please contact me at (954)
768-8210 if you have any questions or require any additional information in connection with this letter.

    Sincerely,

    GREENBERG TRAURIG, P.A.

    By:
     /s/ Flora Perez

     Flora Perez

cc: Talman Pizzey, Chief Executive Officer

Annex A

December 9, 2024
Talman Pizzey
Chief Executive Officer
Acuren Corporation
14434 Medical Complex Drive, Suite 100
Tomball, Texas 77377
Re:Acuren Corporation
Amendment No. 1 to Registration Statement on Form S-4
Filed November 27, 2024
File No. 333-282976
Dear Talman Pizzey:
            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-4 filed on November 27, 2024
Note 3. Business Combinations
Successor Period, page F-42
1.You state that 400 million Acuren British Virgin Islands Ordinary Shares were issued
to ASP Acuren shareholders. It appears that 400,000 shares were issued. Please revise
or advise.
2.Please tell us how the pro forma adjustments described on page F-45 and F-46
resulted in a pro forma net loss of $7.7 million for the Successor nine months ended
September 30, 2024. If applicable, disclose any additional adjustments that you are
making.

December 9, 2024
Page 2
            Please contact Blaise Rhodes at 202-551-3774 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters. Please
contact Scott Anderegg at 202-551-3342 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

September 9, 2024
Talman Pizzey
Chief Executive Officer
Acuren Corporation
14434 Medical Complex Drive, Suite 100
Tomball, Texas 77377
Re:Acuren Corporation
Draft Registration Statement on Form S-4
Submitted on August 12, 2024
CIK No. 0002032966
Dear Talman Pizzey:
            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-4 Submitted on August 12, 2024
Cover Page
1.Please disclose the number of securities you are registering on your Prospectus Cover
Page.
2.We note your disclosure on the Prospectus Cover Page that you "intend to list [your]
common stock on the New York Stock Exchange."  Please revise to clarify whether the
domestication is contingent on your successful listing on the NYSE.  Additionally, please
revise to clarify if you have applied for NYSE listing.  If true, please also revise to clarify
that your warrants and Series A Preferred Stock will not be listed on any national
securities exchange or other principal U.S. market.  Refer to Item 501(b)(4) of Regulation
S-K.  Lastly, please reconcile your cover page disclosure with your disclosure on page 36
that states "[in] connection with the Domestication, we intend to list our Acuren Delaware
common stock and our Warrants on the NYSE."

September 9, 2024
Page 2
ASP Acuren Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 41
3.Please discuss whether supply chain disruptions have materially affected your outlook or
business goals. Specify whether these challenges have materially impacted your results of
operations or capital resources and quantify, to the extent possible, how your sales,
profits, and/or liquidity have been impacted. Revise to discuss known trends or
uncertainties resulting from mitigation efforts undertaken, if any. Explain whether any
mitigation efforts introduce new material risks, including those related to product quality,
reliability, or regulatory approval of products.
Our Growth Strategy
Mergers and Acquisitions, page 63
4.Please expand your disclosure in this section to more fully discuss your acquisition
strategy, including the factors that you will consider in deciding whether or not to acquire
complementary businesses.  Please also revise to indicate any acquisition that are
currently under consideration and describe them or, if none are currently under
consideration, please state this.
Exclusive Forum, page 86
5.We note that the forum selection provision in your bylaws identities the state or federal
court of Delaware as the exclusive forum for certain litigation, including any “derivative
action.” Please disclose whether this provision applies to actions arising under the
Exchange Act. In this regard, we note that Section 27 of the Exchange Act creates
exclusive federal jurisdiction over all suits brought to enforce any duty or liability created
by the Exchange Act or the rules and regulations thereunder. We note your disclosure,
"the federal district courts of the United States will, to the fullest extent permitted by
applicable law, be the sole and exclusive forum for any action asserting a claim arising
under the Securities Act." As it appears that the provision applies to Securities Act claims,
please revise your disclosure to state that there is uncertainty as to whether a court would
enforce such provision, and to state that stockholders will not be deemed to have waived
the company’s compliance with the federal securities laws and the rules and regulations
under it.
Consolidated Financial Statements of ASP Acuren Holdings, Inc.
18. Segment Information, page F-42
6.Please tell us your consideration for disclosing revenues by each product and service
that you identify, such as NDT solutions, RAT solutions, and consulting engineering and
lab testing. Refer to ASC 280-10-50-40.

September 9, 2024
Page 3
            Please contact Blaise Rhodes at 202-551-3774 or Joel Parker at 202-551-3651 if you have
questions regarding comments on the financial statements and related matters. Please contact
Scott Anderegg at 202-551-3342 or Donald Field at 202-551-3680 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services