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                             October 14, 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
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed October 5,
2021
                                                            File No. 333-257240

       Dear Mr. Zeitlin:

               We have reviewed your amended registration statement and have
the following
       comment. Please respond to this letter by amending your registration
statement and providing
       the requested information. After reviewing any amendment to your
registration statement and
       the information you provide in response to this comment, we may have
additional comments.

       Amendment No. 2 to Registration Statement on S-1

       General

   1.                                                   Please update your
financial statements to include the interim period ended June 30, 2021.
                                                        Refer to Rule 8-08 of
Regulation S-X.
              You may contact Eric Atallah at (202) 551-3663 or Daniel Gordon
at (202) 551-3486 if
       you have questions regarding the comment 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.