AJAX I

667 Madison Avenue
New York, NY 10606

October 26, 2020

VIA EMAIL & EDGAR

David Link

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re:	Ajax I (the “Company”)
	Registration Statement on Form S-1 (Registration No. 333-249411)

Dear Mr. Link:

Pursuant to Rule 461(a) of the General Rules and Regulations under the Securities Act of 1933, as amended, we respectfully request that the effective date of the Company’s Registration Statement on Form S-1 (File No. 333-249411) be accelerated by the Securities and Exchange Commission to 4:00 p.m. Washington D.C. time on October 28, 2020 or as soon as practicable thereafter.

We request that we be notified of such effectiveness by a telephone call to Gregg A. Noel of Skadden, Arps, Slate, Meagher & Flom LLP at (213) 687-5234 and that such effectiveness also be confirmed in writing.

Very truly yours,
Ajax I
By:	/s/ J. Morgan Rutman
	Name: J. Morgan Rutman
	Title: Chief Financial Officer

cc:	Skadden, Arps, Slate, Meagher & Flom LLP
	Gregg A. Noel, Esq. and Michael J. Schwartz, Esq.
cc:	Ropes & Gray LLP
	Paul D. Tropp, Esq. and Christopher J. Capuzzi, Esq.