TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo May 1, 2024 Richard Leggett Chief Executive Officer Blue Ocean Acquisition Corp 2 Wisconsin Circle 7th Floor Chevy Chase, MD 20815 Re: Blue Ocean Acquisition Corp Preliminary Proxy Statement Filed April 26, 2024 File No. 001-41112 Dear Richard Leggett: We have reviewed your filing and have the following comments. 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 General 1. We note your disclosure regarding The News Lens Co., Ltd. and your reference to the Form 8-K filed on June 6, 2023. Please clarify the current status of your merger with The News Lens Co., Ltd. Risk Factors We may not be able to complete an initial business combination..., page 16 2. Please revise this risk factor to state clearly whether the SPAC's sponsor is, is controlled by, or has substantial ties with a non-U.S. person and disclose how this fact could impact your ability to complete your initial business combination. 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. Richard Leggett Blue Ocean Acquisition Corp May 1, 2024 Page 2 Please contact Ruairi Regan at 202-551-3269 or Brigitte Lippmann at 202-551-3713 with any questions. Sincerely, FirstName LastNameRichard Leggett Division of Corporation Finance Comapany NameBlue Ocean Acquisition Corp Office of Real Estate & Construction May 1, 2024 Page 2 cc: Kenny S. Terrero, Esq. FirstName LastName