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                              October 11, 2023

       Claudius Tsang
       Chief Executive Officer and Chief Financial Officer
       A SPAC I Mini Acquisition Corp.
       Level 39, Marina Bay Financial Centre
       Tower 2, 10 Marina Boulevard
       Singapore, 018983

                                                        Re: A SPAC I Mini
Acquisition Corp.
                                                            Amendment No. 4 to
Draft Registration Statement on Form F-4
                                                            Submitted on
September 29, 2023
                                                            CIK No. 0001981662

       Dear Claudius Tsang:

            We have reviewed your amended 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.

       Amendment No. 4 to Draft Registration Statement on Form F-4

       Proposal No. 2 - The Acquisition Merger Proposal
       Operational Projections and Assumptions, page 120

   1.                                                   We note your disclosure
that recent developments have caused a significant likelihood
                                                        that NewGenIvf's actual
results over the time periods and under the scenarios covered by
                                                        the projections would
be materially different. We also note that NewGenIvf has not
                                                        updated its projections
at this time. In light of these changed circumstances, please explain
                                                        to us what
consideration you have given to requesting that NewGenIvf update its
                                                        projections. In
addition, please revise your MD&A to discuss in depth these changes in
                                                        circumstances. Refer to
Item 5.A, B and D of Form 20-F. We may have further comment
                                                        after review of the
updated NewGenIvf financial statements that are now required.
 Claudius Tsang
FirstName LastNameClaudius   Tsang
A SPAC I Mini  Acquisition Corp.
Comapany
October 11,NameA
            2023 SPAC I Mini Acquisition Corp.
October
Page 2 11, 2023 Page 2
FirstName LastName
2.       We note your statements here concerning the change in circumstances
since the forecasts
         were prepared. Please revise your Selected Financial Analyses
discussion starting on page
         124 to reflect any similar considerations.
Unaudited Pro Forma Condensed Combined Financial Statements, page 198

3.       We note your expanded disclosure in response to prior comment 4.
Please also (i) quantify
         the number of outstanding warrants and any other securities that were
not included in the
         computation of diluted EPS because to do so would have been
antidilutive and (ii)
         disclose in adjustment (EE) the pertinent terms of the warrants and
any other securities
         (e.g., exercise prices, exercisability provisions, expiration dates,
terms, etc.).
4.       We note your revised disclosure in response to prior comment 5. Please
also address
         whether the Earnout Shares will result in the recognition of a
financial instrument that
         is classified as a liability recognized at fair value with changes in
fair value reflected in
         earnings or a financial instrument classified as equity with no
subsequent
         remeasurement. Provide us any additional analysis to support your
accounting and any
         related pro forma adjustments. If you do not believe a pro forma
adjustment or accounting
         recognition is required for the Earnout Shares, describe this
reasoning, accordingly.
Financial Statements of NewGenIvf Limited
Consolidated Balance Sheets, page F-44

5.       We note your revised disclosure in response to prior comment 6 that
the dividends remain
         subject to the discretion of and approval by the board of directors
and shareholders of
         NewGenIvf after their review of all relevant circumstances including
NewGenIvf   s
         financial results for the period ended and as of June 30, 2023. This
new disclosure appears
         inconsistent with your prior representation that the $.7 million
dividend had already been
         approved by the Board of Directors of NewGenIvf. It also remains
unclear how Board
         approval is substantially different from shareholder approval since
both groups appear to
         be controlled by Mr. Siu and his spouse. Please revise as previously
requested.
Exhibits

6.       Please revise to ensure each exhibit is text-searchable. Refer to Item
301 of Regulation S-
         T.
 Claudius Tsang
FirstName LastNameClaudius   Tsang
A SPAC I Mini  Acquisition Corp.
Comapany
October 11,NameA
            2023 SPAC I Mini Acquisition Corp.
October
Page 3 11, 2023 Page 3
FirstName LastName
       Please contact Michael Fay at 202-551-3812 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Benjamin Richie at 202-551-7857 or Margaret Schwartz at 202-551-7153 with any
other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services
cc:      Giovanni Caruso, Esq.