September 27, 2024

Enrique Klix
Chief Executive Officers
Integral Acquisition Corp 1
11330 Avenue of the Americas
23rd Floor
New York, NY 10019

       Re: Integral Acquisition Corp 1
           Preliminary Proxy Statement on Schedule 14A
           Filed September 20, 2024
           File No. 001-41006
Dear Enrique Klix:

       We have reviewed your filing and have the following comment.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Preliminary Proxy Statement on Schedule 14A
Risk Factors
Even if the Third Extension Amendment Proposal is approved by our
stockholders..., page 17

1.     We note your disclosure in this risk factor regarding the potential for
delisting given that
       you are seeking to extend your termination date to a date that is over
36 months from your
       initial public offering. Because Section IM-5101- 2 of the Nasdaq
listing rules requires
       that a special purpose acquisition company complete a business
combination within 36
       months of the effectiveness of the initial public offering registration
statement, and in
       light of SEC Release No. 34-100538, please clearly disclose that your
shares will be
       delisted if you are not able to complete a business combination by
November 2, 2024, and
       disclose the risks associated with being delisted, including that you
may no longer be
       attractive as a merger partner.
 September 27, 2024
Page 2

        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 Stacie Gorman at 202-551-3585 or Pam Howell at
202-551-3357 with any
other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Real Estate
& Construction
cc:   Jonathan Deblinger, Esq.