SecProbe.io

CORRESP
 1
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 May 13, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: Wen Acquisition Corp

 Registration Statement on Form S-1

 File No. 333-286872

 Ladies and Gentlemen:

 In accordance with Rule 461
under the Securities Act of 1933, as amended (the "Securities Act"), the undersigned, as representative of the underwriters
for the proposed public offering of units of Wen Acquisition Corp (the "Company") pursuant to the above-referenced Registration
Statement, hereby joins in the request of the Company for acceleration of the effective date of the above-referenced Registration Statement
so that it becomes effective at 4:30 p.m., Eastern Time, on Thursday, May 15, 2025, or as soon as possible thereafter.

 Pursuant to Rule 460 of the
General Rules and Regulations under the Securities Act, the undersigned advises 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 Exchange Act of 1934, as amended,
in connection with the above-referenced proposed offering.

 [ Signature Page Follows ]

 Very truly yours,

 CANTOR FITZGERALD & CO.

 By:
 /s/ David Batalion

 Name:
 David Batalion

 Title:
 Managing Director, Investment Banking

 [ Signature Page to SEC Letter from Underwriters
Requesting Acceleration of Effectiveness ]

CORRESP
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 WEN ACQUISITION CORP

 180 Grand Avenue, Suite 1530

 Oakland, CA 94612

 May 13, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, N.E.

 Washington, DC 20549

 Attention:
 Jeffrey Lewis

 Isaac Esquivel

 Ruairi Regan

 Mary Beth Breslin

 Re:
 Wen Acquisition Corp

 Registration Statement on Form S-1

 Initially Filed April 30, 2025, as amended File No. 333-286872

 Dear Ruairi Regan:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Wen Acquisition Corp hereby requests acceleration of effectiveness of the above referenced Registration
Statement so that it will become effective at 4:30 p.m. ET on Thursday, May 15, 2025, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Julian Sevillano

 Julian Sevillano

 Chief Executive Officer

 cc:
 Ellenoff Grossman & Schole LLP

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 March 24, 2025

Julian Sevillano
Chief Executive Officer
WEN Acquisition Corp
180 Grand Avenue
Suite 1530
Oakland, CA 94612

 Re: WEN Acquisition Corp
 Draft Registration Statement on Form S-1
 Submitted February 25, 2025
 CIK No. 0002057043
Dear Julian Sevillano:

 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
Cover Page

1. Please describe on the cover page and in the summary the anti-dilution
adjustments
 that may result in the issuance of additional securities to the sponsor,
its affiliates and
 promoters in connection with any change in the size of the offering to
maintain the
 number of founder shares at 20% upon the offering s consummation. We
note your
 disclosure on page 19 that you may increase or decrease the size of the
offering
 pursuant to Rule 462(b) under the Securities Act. Please disclose on the
cover page
 whether and the extent to which these securities issuances may result in
a material
 dilution of the purchaser s equity interests, as required by Items
1602(a)(3) of
 Regulation S-K.
 March 24, 2025
Page 2

Proceeds to be held in trust account, page 22

2. Please reconcile the disclosure in this section that funds held in the
trust account may
 be released to pay taxes with the disclosure on page 51 that funds may
be released to
 pay certain other expenses and on page 89 which references the release
of funds up to
 $100,000 to pay dissolution expenses.
Conflicts of Interest, page 33

3. We note your disclosure that your sponsor, officers and directors could
have conflicts
 of interest in determining whether to present business combination
opportunities to
 you or to any other SPAC with which they may become involved. Please
revise your
 conflicts disclosure to reflect the current involvement of certain
members of your
 management with existing SPACs such as Launch One Acquisition Corp and
Launch
 Two Acquisition Corp and clarify how opportunities to acquire targets
are allocated
 among SPACs. See Items 1602(b)(7) and 1603(b) of Regulation S-K.
Dilution, page 92

4. We refer to your tables beginning on page 92 showing your calculations
of net
 tangible book value presented in quartile intervals assuming full
exercise and no
 exercise of the over-allotment option. It appears the calculations
labeled With Over-
 Allotment are made assuming no exercise of the over-allotment option
and the
 calculations labeled Without Over-Allotment are made assuming full
exercise of the
 over-allotment option. Please reconcile and revise your presentation
throughout your
 filing to properly label the assumptions used in your calculations.
5. Please expand your disclosure outside the table to highlight that you
may need to issue
 additional securities as you intend to seek an initial business
combination with a target
 company with an enterprise value greater than the net proceeds of the
offering and the
 sale of private placement warrants, as stated on page 10 of your
prospectus.
SPAC Experience, page 101

6. For each of the SPAC business combinations referenced in this section
please revise
 to disclose the financing needed for the transactions. Also, disclose
the level of
 redemptions for FTAC Olympus Acquisition Corp.
Restrictions on Transfers of Founder Shares and Private Placement Warrants,
page 147

7. Please reconcile your disclosure in this section regarding the transfer
of securities by
 Cantor Fitzgerald with the disclosure on pages 13 and 112.
 March 24, 2025
Page 3

 Please contact Jeffrey Lewis at 202-551-6216 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 Mary Beth Breslin at
202-551-3625
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real Estate
& Construction
cc: Stuart Neuhauser, Esq.
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