United States securities and exchange commission logo





                             March 17, 2021

       Subash Menon
       Chief Executive Officer
       Bannix Acquisition Corp.
       300 Tice Boulevard; Suite 315
       Woodcliff Lake, New Jersey 07677

                                                        Re: Bannix Acquisition
Corp.
                                                            Registration
Statement on Form S-1
                                                            Filed February 19,
2021
                                                            File No. 333-253324

       Dear Mr. Menon:

              We have reviewed your registration statement and have the
following comments. In
       some of our comments, we may ask you to provide us with information so
we may better
       understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.

       Form S-1 filed February 19, 2021

       Prospectus Cover Page, page i

   1.                                                   On page 11, you
disclose that the company agreed to grant to I-Bankers 300,000 warrants
                                                        (or 345,000 warrants if
the underwriters    over-allotment option is exercised in full) upon
                                                        the closing of this
offering. Please revise the cover page to include this grant.
       Our Company, page 2

   2.                                                   Clarify how the growth
of the Global Customer Solutions Engagement market is being
                                                        measured in the chart.
 Subash Menon
FirstName  LastNameSubash
Bannix Acquisition Corp. Menon
Comapany
March      NameBannix Acquisition Corp.
       17, 2021
March2 17, 2021 Page 2
Page
FirstName LastName
Our Acquisition Process, page 7

3.       We note your intention to engage third parties "when needed" in
seeking an appropriate
         acquisition target. Disclose whether you are limited as to how much of
the proceeds from
         this offering can be used to pay for the services of such third
parties.
Certain Relationships and Related Party Transactions, page 102

4.       We note that I-Bankers will be purchasing 1,000,000 warrants in the
offering and
         transferring those warrants to the sponsors. Please explain the
business reasons for
         structuring this purchase in this manner.
Underwriting, page 123

5.       Explain the difference between, and business purpose behind, the
Representative's Shares
         and Founder Shares being issued to I-Bankers.
        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.

        Refer to Rule 461 regarding requests for acceleration. Please allow
adequate time for us
to review any amendment prior to the requested effective date of the
registration statement.

        You may contact Joyce Sweeney, Staff Accountant, at (202) 551-3449 or
Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Alexandra
Barone, Staff
Attorney, at (202) 551-8816 or Larry Spirgel, Office Chief, at (202) 551-3815
with any other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology