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                              December 11, 2023

       Jide Zeitlin
       Co-Chief Executive Officer
       bleuacacia ltd
       500 Fifth Avenue
       New York, NY 10110

                                                        Re: bleuacacia ltd
                                                            Preliminary Proxy
Statement on Schedule 14A
                                                            Filed December 1,
2023
                                                            File No. 001-41074

       Dear Jide Zeitlin:

                                                        We have reviewed your
filing and have the following comment.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Preliminary Proxy Statement on Schedule 14A

       General

   1.                                                   We note that your
sponsor, bleuacacia sponsor LLC, is a Cayman Islands limited liability
                                                        company. With a view
toward disclosure, please tell us whether your sponsor is also
                                                        controlled by or has
substantial ties with a non-U.S. person. Revise to include risk factor
                                                        disclosure that
addresses how the fact that your sponsor is itself a non-U.S. person, and, if
                                                        true, is controlled by,
has any members who are, or has substantial ties with, a non-U.S.
                                                        person, could impact
your ability to complete your initial business combination. For
                                                        instance, discuss the
risk to investors that you may not be able to complete an initial
                                                        business combination
with a U.S. target company should the transaction be subject to
                                                        review by a U.S.
government entity, such as the Committee on Foreign Investment in the
                                                        United States (CFIUS),
or ultimately prohibited. Disclose that as a result, the pool of
                                                        potential targets with
which you could complete an initial business combination may be
                                                        limited. Further,
disclose that the time necessary for government review of the transaction
                                                        or a decision to
prohibit the transaction could prevent you from completing an initial
                                                        business combination
and require you to liquidate. Disclose the consequences of
 Jide Zeitlin
bleuacacia ltd
December 11, 2023
Page 2
       liquidation to investors, such as the losses of the investment
opportunity in a target
       company, any price appreciation in the combined company, and the
warrants, which
       would expire worthless.
        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.

       Please contact Kibum Park at 202-551-6836 or Mary Beth Breslin at
202-551-3625 with
any other questions.



                                                             Sincerely,
FirstName LastNameJide Zeitlin
                                                             Division of
Corporation Finance
Comapany Namebleuacacia ltd
                                                             Office of Real
Estate & Construction
December 11, 2023 Page 2
cc:       Valerie Ford Jacob, Esq.
FirstName LastName