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                             March 24, 2022

       James Francis
       Chief Executive Officer
       ESH Acquisition Corp.
       228 Park Ave S, Suite 89898
       New York, New York 10003-1502

                                                        Re: ESH Acquisition
Corp.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted March 22,
2022
                                                            CIK No. 0001918661

       Dear Mr. Francis:

                                                        This is to advise you
that we do not intend to review your registration statement.

               We request that you publicly file your registration statement
and nonpublic draft
       submissions at least 15 days prior to any road show as that term is
defined in Rule 433(h)(4) or,
       in the absence of a road show, at least 15 days prior to the requested
effective date of the
       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 Shih-Kuei Chen at 202-551-7664 or Ruairi Regan at
202-551-3269 with
       any questions.




                             Sincerely,


                             Division of Corporation Finance

                             Office of Real Estate & Construction
       cc:                                              Sean M. Ewen, Esq.