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                              July 2, 2021

       Jide Zeitlin
       Co-Chief Executive Officer
       bleuacacia ltd
       c/o The Keffi Group Ltd
       500 Fifth Avenue
       New York, New York 10110

                                                        Re: bleuacacia ltd
                                                            Registration
Statement on Form S-1
                                                            Filed June 21, 2021
                                                            File No. 333-257240

       Dear Mr. Zeitlin:

              We have reviewed your registration statement and have the
following comment. In our
       comment 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 comment applies 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 this comment, we may have additional comments.

       Form S-1 filed June 21, 2021

       General

   1.                                                   We note that you have
replaced the term "senior advisors" with the term "partners"
                                                        throughout the
prospectus; however, it does not appear the referenced individuals are
                                                        party to a partnership
arrangement, necessitating the use of the term. If a partnership
                                                        arrangement does exist,
please provide disclosure briefly explaining the arrangement and
                                                        file any related
material agreements. In the event no partnership exists, please revise the
                                                        term to more
appropriately characterize the relationship of the individuals with the
                                                        company.
 Jide Zeitlin
FirstName   LastNameJide Zeitlin
bleuacacia ltd
Comapany
July 2, 2021Namebleuacacia ltd
July 2,2 2021 Page 2
Page
FirstName LastName
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Eric Atallah at (202) 551-3663 or Daniel Gordon at (202)
551-3486 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Abby Adams at (202) 551-6902 or Laura Crotty at (202)551-7614 with any
other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:      Valerie Ford Jacob, Esq.