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                              February 8, 2022

       Manoj Jain
       Chief Executive Officer
       Duddell Street Acquisition Corp.
       8/F Printing House
       6 Duddell Street
       Hong Kong

                                                        Re: Duddell Street
Acquisition Corp.
                                                            Amendment No. 1 to
Registration Statement on Form S-4
                                                            Filed January 10,
2022
                                                            File No. 333-261483

       Dear Mr. Jain:

             We have reviewed your amended 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.
Unless we note
       otherwise, our references to prior comments are to comments in our
December 30, 2021 letter.

       Amendment No. 1 to Registration Statement on Form S-4 Filed January 10,
2022

       Cover Page

   1.                                                   We note your revisions
in response to comment 2. While you note that laws and
                                                        regulations of the
People's Republic of China do not currently have any impact on DSAC's
                                                        business, financial
condition and results of operations, your disclosure in this section does
                                                        not affirmatively state
whether you are required to receive any permissions or approvals
                                                        from PRC governmental
authorities to consummate this transaction and/or offer the
                                                        securities being
registered to foreign investors. You disclose in your Risk Factors section
                                                        that no permission is
required under the Opinions from any PRC governmental authority,
                                                        including the China
Securities Regulatory Commission; however your disclosure
 Manoj Jain
FirstName LastNameManoj     Jain
Duddell Street Acquisition Corp.
Comapany8,NameDuddell
February   2022          Street Acquisition Corp.
February
Page 2 8, 2022 Page 2
FirstName LastName
         regarding approval by the Cyberspace Administration of China (CAC) is
less clear.
         Please revise this section to disclose specifically whether DSAC,
FiscalNote, or any
         affiliated entity are covered by permissions requirements from the
China Securities
         Regulatory Commission (CSRC), CAC or any other governmental agency
that is required
         to consummate the transactions or issue the securities being
registered to foreign
         investors. If any such approval is required, please state
affirmatively whether you have
         received all requisite permissions or approvals and whether any
permissions or approvals
         have been denied. Please also describe the consequences to you and
your investors if you
         (i) do not receive or maintain such permissions or approvals, (ii)
inadvertently conclude
         that such permissions or approvals are not required, or (iii)
applicable laws, regulations or
         interpretations change and you are required to obtain such permissions
or approvals.
         Please make conforming changes elsewhere in your prospectus as
appropriate.
2.       Please disclose the location of the principal executive offices of the
company post-
         Business Combination. Please also disclose prominently on the cover
page that, if true,
         you are not, and will not, undertake an initial business combination
with any entity with
         principal business operations in China, Hong Kong, or Macau. Finally,
please confirm
         whether DSAC's IPO proceeds are in a trust account located in the U.S.
3.       Please revise to indicate the percentage of economic and voting
interest that Tim Hwang
         and Gerald Yao will hold following the closing of the Business
Combination. Please
         clearly indicate that Tim Hwang and Gerald Yao will be able to control
all matters
         requiring stockholder or board approval, and provide examples of such
matter. Please
         provide similar disclosure elsewhere that you discuss the ownership of
Class B holders,
         and clearly state that the Class B holders are Tim Hwang and Gerald
Yao.
4.       Please revise here and in the Letter to Shareholders to clearly state
the economic and
         voting interests that will be held by the DSAC public shareholders,
the Class A FiscalNote
         holders, the Class B FiscalNote holders, the Sponsor (including
backstop shares), and the
         PIPE investors following completion of the Business Combination.
Please include total
         potential ownership interest in the combined company, assuming
exercise and conversion
         of all securities, such as the private placement warrants. Please also
revise the diagram on
         page 33 to separately present the ownership interest for each category
of holders. Please
         include similar disclosure elsewhere in your filing as appropriate.
What equity stake will current DSAC shareholders and FiscalNote
shareholders..., page 15

5.       We note your response to comment 4. Please revise the sensitivity
analysis to show the
         potential impact based on an interim redemption level. While you note
that the Backstop
         Agreement means that the amount in the trust account will remain the
same, the number
         of shares owned by non-redeeming shareholders will change depending on
the redemption
         level. Please also disclose the percentage held by the sponsor
affiliate(s) who may
         purchase shares under the Backstop Agreement. Please also disclose
total potential
         ownership here, and elsewhere that such ownership information is
presented, assuming
         exercise and conversion of all securities.
 Manoj Jain
FirstName LastNameManoj     Jain
Duddell Street Acquisition Corp.
Comapany8,NameDuddell
February   2022          Street Acquisition Corp.
February
Page 3 8, 2022 Page 3
FirstName LastName
6.       We note your response to comment 14 that underwriting fees remain
constant and are not
         subject to redemption or backstop purchase adjustments. Given that
such fees are
         constant, please disclose, on a percentage basis, what the effective
underwriting fee is
         based on various levels of redemption. Specifically, disclose the
underwriting fee as a
         percentage of proceeds raised in the IPO based on no redemptions, an
interim level of
         redemptions, or maximum redemptions. Your calculations should not take
into account
         the Backstop Agreement.
Summary of the Proxy Statement/Prospectus, page 31

7.       Please disclose whether your auditor is subject to the determinations
announced by the
         PCAOB on December 16, 2021 and whether and how the Holding Foreign
Companies
         Accountable Act and related regulations will affect your company.
8.       We note your amended disclosure in response to comment 9 and we
reissue it. In your
         summary of risk factors, disclose the risks that being based in Hong
Kong poses to
         investors who will hold shares in the combined company. In particular,
describe the
         significant regulatory, liquidity, and enforcement risks with
cross-references to the more
         detailed discussion of these risks in the prospectus. For example,
specifically discuss risks
         arising from the legal system in China, including risks and
uncertainties regarding the
         enforcement of laws and that rules and regulations in China can change
quickly with little
         advance notice; and the risk that the Chinese government may intervene
or influence your
         operations at any time, or may exert more control over offerings
conducted overseas
         and/or foreign investment in China-based issuers, which could result
in a material change
         in your operations and/or the value of your common stock. Acknowledge
any risks that
         any actions by the Chinese government to exert more oversight and
control over offerings
         that are conducted overseas and/or foreign investment in China-based
issuers could
         significantly limit or completely hinder your ability to offer or
continue to offer securities
         to investors and cause the value of such securities to significantly
decline or be worthless.
         Specifically address how these risks could impact your ability to
successfully complete
         the Business Combination, as applicable, and whether, and if so how,
these risks will
         apply to the post-Business Combination company.
Risk Factors, page 70

9.       We note your amended disclosure in response to comment 16. Please
revise to
         specifically state that the Chinese government may intervene or
influence your operations
         at any time, which could result in a material change in your
operations and/or the value of
         your Common Stock. Also, we note your statement that "[a]ny such
action, once taken by
         the PRC government towards a company with Hong Kong nexus as DSAC
locates in
         Hong Kong, even if FiscalNote does not have any substantive operations
in mainland
         China, could significantly limit or completely hinder our ability to
consummate the
         Business Combination or New FiscalNote   s ability to offer or
continue to offer securities
         to investors and cause the value of such securities to significantly
decline or in extreme
         cases, become worthless." (Emphasis added). Please revise to state
whether FiscalNote
 Manoj Jain
FirstName LastNameManoj     Jain
Duddell Street Acquisition Corp.
Comapany8,NameDuddell
February   2022          Street Acquisition Corp.
February
Page 4 8, 2022 Page 4
FirstName LastName
         has any substantive operations in Hong Kong and remove your reference
to "or in
         extreme cases," as indicated above. Please provide specific disclosure
regarding the risk
         that the PRC government could hinder your ability to consummate the
Business
         Combination, including the ways in which the PRC government could do
so and the
         efforts or inquiries you have made to mitigate such potential risks.
10.      We note your amended disclosure in response to comment 17, including
that New
         FiscalNote's operations could be influenced by China's government.
Specifically, we note
         your statement that "[i]f any or all of the foregoing were to occur,
it could lead to a
         material adverse change in our operations and limit or hinder New
FiscalNote   s ability to
         offer securities to overseas investors or remain listed in the U.S.,
which could cause the
         value of New FiscalNote   s shares to significantly decline or become
worthless." Please
         provide additional information on the Chinese government's influence
on New FiscalNote,
         including the specific ways in which it could influence New
FiscalNote's operations or
         cause the value of its shares to significantly decline or become
worthless. Please also
         clarify whether the Chinese government has any existing ties,
affiliations, investments or
         control over FiscalNote.
We have significant operations and assets in..., page 87

11.      In your response to comment 29, you note that FiscalNote's revenues in
Asia, including
         Hong Kong or China, are not material. In light of your response,
please tell us what
         "significant operations and assets" are located in Hong Kong, as
stated in this risk factor.
"FiscalNote has incurred a significant amount of debt ... ", page 90

12.      We note your amended disclosure in response to comment 20. Please
disclose which of
         the outstanding debt you intend to repay at the closing of the
Business Combination.
Background of the Business Combination, page 117

13.      We note your amended disclosure in response to comment 23. Please
disclose
         information relating to the comparable precedent transactions between
2018 and March
         2021, including identifying the transactions and the data from the
transactions were used
         in determining the earnout consideration.
14.      We note your response to comment 25 and your amended disclosure on
page 123
         regarding Citi's role in preparing presentation materials. Please
supplementally explain
         why the report provided by Citi is not materially related to the
transaction. It is unclear
         from your response why the fact that the valuation of FiscalNote was
analyzed and
         determined by DSAC   s management and reviewed and approved by the
DSAC Board
         before execution of the Business Combination Agreement means that the
Citi report is not
         material. Alternatively, please provide the information required by
Item 1015(b) of
         Regulation M-A, and file any written materials, as well as the consent
of the outside
         party, as exhibits, or explain in further detail why you are not
required to do so. Please
         refer to Item 4(b) of Form S-4.
 Manoj Jain
Duddell Street Acquisition Corp.
February 8, 2022
Page 5
15.      We note your amended disclosure in response to comment 24. While you
list the topics
         discussed, it is unclear what about these particular topics was
discussed, how issues were
         resolved, and how this impacted the transaction. As one example, you
note that DSAC
         expressed its preference or an optimal capital structure and discussed
with FiscalNote
         what the optimal amount of debt would be, but the specifics of the
optimal amount of debt
         are not disclosed. Similarly, it's unclear what FiscalNote presented
about the financial
         projection assumptions. Please revise accordingly.
DSAC Board Reasons for the Approval of the Business Combination, page 124

16.      We note your amended disclosure in response to comment 28. Please
revise to
         specifically state whether the DSAC Board considered the consideration
to be offered in
         the Business Combination in evaluating and recommending the Business
Combination.
         To the extent that the DSAC Board did evaluate the consideration,
please revise to state as
         much and disclose whether the DSAC Board considered the transaction to
be fair. To the
         extent the DSAC Board did not evaluate the consideration, please
revise to state as much
         and disclose whether the DSAC Board continues to recommend the
Business
         Combination.
17.      We note your response to comment 30 and we reissue it. Please revise
your Background
         of the Business Combination section to include any material
discussions relating to these
         factors, such as FiscalNote   s geographic locations, operations, and
customer base.
Financial Analysis, page 126

18.      We note your amended disclosure in response to comment 33 and we
reissue it in part.
         Please revise to include the additional analyses and projections that
are included in the
         Investor Presentation in the registration statement.
Selected Public Company Analysis, page 127

19.      We note your amended disclosure in response to comment 31. Please
revise to explain the
         methodology for determining the Revenue Estimates for 2021-2023 for
the selected public
         companies.
Conflicts of Interest, page 134
FirstName LastNameManoj Jain
20.    We note your amended disclosure in response to comment 58. Please revise
to include
Comapany    NameDuddell
       the table           Street
                 summarizing   theAcquisition  Corp. your officers and
directors currently have
                                   entities to which
       fiduciary
February  8, 2022duties
                  Page 5or contractual obligations.
FirstName LastName
 Manoj Jain
FirstName LastNameManoj     Jain
Duddell Street Acquisition Corp.
Comapany8,NameDuddell
February   2022          Street Acquisition Corp.
February
Page 6 8, 2022 Page 6
FirstName LastName
Ancillary Agreements Related to the Business Combination
Backstop Agreement, page 142

21.      We note your description of the Backstop Agreement. Please revise
here, and elsewhere
         throughout your prospectus as appropriate, to disclose:

                who the certain affiliates of the sponsor are who entered into
the Backstop
              Agreement;
                how the sponsor and its affiliates benefit from the Backstop
Agreement. For
              example, disclose that the public stockholders currently hold a
collective 10.6% of
              your shares may vote against the Business Combination and redeem
their shares, but
              despite this, the Business Combination could still be approved
and there would be a
              sufficient amount of cash in the SPAC's trust account following
the public
              shareholders' redemptions; and
                whether and to what extent the parties to the Backstop
Agreement have additional
              interests in the Business Combination.

         Please also revise your Risk Factors, as appropriate, and file the
Backstop Agreement as
         an exhibit.
CFIUS Approval, page 154

22.      Please disclose the reason why CFIUS approval is needed for Manoj Jain
and an
         additional director to serve on the New FiscalNote Board.
Business of FiscalNote, page 200

23.      We note your response to comment 40. Please revise to include your
response in the
         comment letter as disclosure in this section.
Acquisition Opportunities, page 203

24.      We note your amended disclosure in response to comment 42, including
that FiscalNote
         is "tracking" 80 companies. Please revise to elaborate on what you
mean by "tracking."
         Please also revise to disclose that you are in various stages of
discussions with 20 of the
         companies. Additionally, we note that your investor presentation
included in the Duddell
         Street Form 8-K filed on November 8, 2021 indicates on slide 29 that
you have identified
         over 900 targets, shortlisted 55 targets and have entered into
discussions or LOIs with 17
         targets. Please advise.
FiscalNote's Management's Discussion and Analysis of Financial Condition and
Results of
Operations
Key Performance Indicators and Non-GAAP Measures, page 212

25.      We note that your Investor Presentation includes Average Account Value
and Annual
         Contract Value as metrics. Please tell us whether you consider these
metrics to be key
 Manoj Jain
Duddell Street Acquisition Corp.
February 8, 2022
Page 7
      performance indicators and if not, why not.
Beneficial Ownership of Securities, page 254

26.   We note the 5% Beneficial Owners of New FiscalNote, including FN SPV
Holdings Pty
      Ltd, Radical Investments LP, and Visionnaire Ventures Fund I, L.P. Please
provide the
      information required by Item 403 of Regulation S-K, including the natural
person or
      persons who have voting and investment control of the shares held by
these entities.
New FiscalNote Management After the Business Combination, page 257

27.   We note that Manoj Jain and another individual are to serve as a
directors of New
      FiscalNote pending CFIUS approval. However, we note that they are not
included in the
      chart on page 257 that depicts New FiscalNote Management After the
Business
      Combination. Please revise.
U.S. Federal Income Tax Considerations, page 276

28.   We note your response and amended disclosure to comment 52 and we reissue
it in
      part. Please include disclosure of the material tax consequences of the
Business
      Combination, and provide a tax opinion to the extent required. In this
regard, we note that
      the Merger Agreement indicates that the parties intend for the merger to
qualify as a
      reorganization under Section 368(a). If there is uncertainty regarding
the tax treatment of
      the transactions, counsel may issue a "should" or "more likely than not"
opinion to make
      clear that the opinion is subject to a degree of uncertainty, and explain
why it cannot give
      a firm opinion. Please make similar revisions where you discuss the tax
consequences of
      the transaction, and include risk factor disclosure, as appropriate.
Refer to Section III of
      Staff Legal Bulletin 19.
       You may contact Keira Nakada at (202) 551-3659 or Lyn Shenk at (202)
551-3380 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Cara Wirth at (202) 551-7127 or Erin Jaskot at (202) 551-3442 with any
other questions.



                                                            Sincerely,
FirstName LastNameManoj Jain
                                                            Division of
Corporation Finance
Comapany NameDuddell Street Acquisition Corp.
                                                            Office of Trade &
Services
February 8, 2022 Page 7
cc:       James C. Lin
FirstName LastName