October 25, 2024

John Brenman
Chief Executive Officer
Swiftmerge Acquisition Corp.
4318 Forman Ave
Toluca Lake, CA 91602

Tristan Yopp
Chief Financial Officer
AleAnna Energy, LLC
Crecent Court, Suite 1860
Dallas, TX 75201

       Re: Swiftmerge Acquisition Corp.
           AleAnna Energy, LLC
           Amendment No. 1 to Registration Statement on Form S-4
           Filed October 8, 2024
           File No. 333-280699
Dear John Brenman and Tristan Yopp:

     We have reviewed your amended registration statement and have the
following
comment(s).

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a 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 letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our August 6,
2024 letter.

Amendment No. 1 to Form S-4 filed on October 8, 2024
Proxy Statement/Prospectus Summary
Dilution, page 37

1.     We note you disclose here and elsewhere in your proxy
statement/prospectus the net
       tangible book value per share as adjusted for the following redemption
scenarios - No
 October 25, 2024
Page 2

       Additional Redemptions, 50% Redemption Scenario, and Maximum Redemption.
       Please expand your disclosure to include a range of redemption scenarios
that will
       reasonably inform investors of potential outcomes.
Risks Related to SPAC
BofA, as underwriters of the Initial Public Offering, was to be compensated in
part on a
deferred basis in connection with the Initial, page 113

2.     We note your revised disclosure in response to prior comment 13. Please
expand to
       disclose the reasons BofA agreed to waive its remaining deferred fees.
SPAC does not have a specified maximum redemption threshold, page 116

3.     We note your revised disclosure in response to prior comment 15. Please
expand your
       disclosure to discuss the impact that the trust falling below $5,000,001
may have on
       SPAC's listing on Nasdaq or tell us why you believe this does not
present a material
       risk.
Unaudited Pro Forma Condensed Combined Financial Information
Note 3 - Transaction Accounting Adjustments, page 127

4.     Refer to footnote 5 on page 127. We note you purchased two renewable
natural gas
       plants in July 2024 and reflected these transactions as asset
acquisitions within your
       pro forma financial statements. Based on your disclosure it appears you
have not
       concluded on whether these acquisitions should have been accounted for
and reflected
       within the proforma financial statements as business combinations under
ASC 805.
       Please provide to us your accounting analysis for these two
transactions.
Background to the Business Combination, page 156

5.     We note your revised disclosure in response to prior comment 22 and
reissue the
       comment in part. Please revise your disclosure throughout this section
to discuss in
       greater detail the material terms that were negotiated by the parties,
how parties
       positions differed, and how issues were resolved. Your revised
disclosure should
       disclose the initial pre-money valuation that was the basis for the
consideration
       included in the letter of intent executed on April 1, 2024 that was
later increased to
       $665,000,000 in the updated letter of intent and how the initial
pre-money valuation
       was determined. In that regard, we note you disclose that AleAnna
submitted the
       initial transaction terms by way of a draft non-binding letter of
intent. In addition,
       please clarify the date the updated letter of intent was executed and
discuss the
       negotiation of the board representation. To the extent certain terms
were deemed not
       subject to negotiation, disclose this fact.

6.     We note your disclosure that SPAC management initially learned of
AleAnna on or
       about March 11, 2024 from an affiliate of the sponsor of a special
purpose acquisition
       company. However, your disclosure on page 164 states that Pureplay
       introduced SPAC to AleAnna in March 2024. Please advise or revise. In
addition,
       please expand your disclosure to clarify Pureplay's role in the business
combination
       and any related negotiations.
 October 25, 2024
Page 3

7.    We note your revised disclosure in response to prior comment 23. We also
note your
      disclosure that on or about September 20, 2024, Cohen entered into a
release and
      termination agreement with SPAC, in which those parties agreed to reduce
the
      advisory fee to which Cohen would be entitled upon closing of the
Business
      Combination from $3,000,000 to $500,000. Please revise to clarify Cohen
s role
      regarding your business combination with AleAnna and related agreements
and
      disclose the reason that Cohen agreed to reduce its advisory fee. Discuss
whether
      there were any disagreements or objections made to the disclosure in the
filing. Also,
      address the material impact, if any, of agreement provisions that survive
SPAC's
      release and termination agreement with Cohen, such as indemnification,
contribution,
      rights of first refusal or lockups.

SPAC's Valuation of AleAnna, page 170

8.    We note your disclosure regarding certain unaudited prospective
information supplied
      by AleAnna to SPAC in connection with the proposed business combination,
      including the DeGolyer & MacNaughton reserves estimate and AleAnna   s
RNG
      prospect backlog information. Please disclose whether or not AleAnna has
affirmed to
      SPAC that its prospective information reflects its view about its future
performance as
      of the most recent practicable date prior to the date of the proxy
statement/prospectus.
      If the prospective information no longer reflect the views of AleAnna's
management
      or board of directors regarding its future performance as of the most
recent practicable
      date prior to the date of the proxy statement/prospectus, clearly state
the purpose of
      disclosing the prospective information and the reasons for any continued
reliance by
      management or board of directors on the prospective information. Refer to
Item
      1609(c) of Regulation S-K.
9.    Please describe in greater detail the comparable companies analysis
utilized to analyze
      AleAnna's potential RNG business and the basis for determining that the
average
      RNG facility could be expected to generate EBITDA of $1.65 million and
reach
      payout in approximately four years from being brought on stream.
Reserve Information
Reserve Data, page 224

10.   Disclosures in Amendment No. 1 on pages 225-226, 238, and F-77 state the
      acquisition of the Blugas ORRI would have increased future net cash flows
and the
      standardized measure, as of December 31, 2023, by $35.3 million and $30.0
million,
      respectively; however, disclosures on pages 240 and 247 state the future
net cash
      flows would have increased by $34.9 million. Please review and revise to
remove the
      inconsistency.

      In addition, please disclose:
          the change in the Company   s net revenue interest as a result of the
Blugas ORRI
          acquisition,
          if there was a change in the Company   s net proved reserves as a
result of the
          Blugas ORRI acquisition, and
 October 25, 2024
Page 4

             if the total $6.6 million in acquisition costs were included in
the evaluation of the
           Blugas ORRI acquisition, as of December 31, 2023.
11.   In comparing the net gas volume associated with the Blugas ORRI
acquisition
      disclosed in Amendment No. 1 (2,472 103ft3, thousand cubic feet, or Mcf)
versus the
      net gas volume contained in the reserve report filed as Exhibit 99.7
(2,472 106ft3,
      million cubic feet, or MMcf), we note an inconsistency in the units of
measure. Please
      review and revise to remove the inconsistency throughout the filing.

      Additionally, please expand your disclosure of the 350 million cubic
meters of natural
      gas associated with the Blugas ORRI throughout the filing to provide the
cubic feet
      equivalent.
Standardized Measure of Discounted Future Net Cash Flows Relating to Proved
Natural Gas
Reserves, page 225

12.   Amendment No. 1 still states the table on page 225 provides the estimated
future net
      cash flows and the present value of the net cash flows discounted at 10%
(PV10).
      However, the two items shown in the table are: 1) Future net cash flow
and 2)
      Standardized measure of discounted future net cash flow. Based on the
description of
      these items in the table footnotes on pages 225-226 and in Note 13 on
page F-78, we
      note:

             Future net cash flow appears to be incorrectly calculated as after
deducting future
           income taxes, but prior to discounting at 10%. At the bottom of page
225 and in
           Note 13, your filing incorrectly states the future net cash flows
are net of
           estimated income taxes. However, also on page 225, your filing
correctly states
           "Future cash flows are reduced by estimated production costs,
administrative
           costs, costs to develop and produce the proved reserves and
abandonment costs,
           all based on current economic conditions at each year-end.    The
correct
           calculation of future net cash flow is prior to discounting at 10%
and prior to the
           deduction of future income taxes. Please review and revise your
filing where
           necessary to correct the calculation of future net cash flows and to
provide an
           accurate description.
             Present value discounted at 10% (PV10) is not included in the
table. The correct
           calculation of present value is after discounting the estimated
future net cash
           flows at 10%, but prior to the deduction of future income taxes.
Please review and
           expand the table to include the present value (PV10), if desired,
and to provide an
           accurate description. Otherwise, revise the description of the table
to state it
           includes the estimated future net cash flows and the standardized
measure.
             The table's explanatory footnotes are confusing and include
descriptions of
           multiple items, e.g. footnote (a) to future net cash flow on page
225, includes
           information on gas prices, revisions/extensions and discoveries, and
changes in
           the standardized measure. Please revise the table footnotes to
describe each
           footnoted item more accurately.

      In addition, please review and revise the standardized measure summary
table on page
 October 25, 2024
Page 5

      F-78 to present the component items and their associated values in the
correct order of
      calculation and revise the table footnotes to describe each footnoted
item more
      accurately. For additional guidance, refer to Example 5 in FASB ASC
932-235-55-6.
Acreage, page 226

13.   We note the updated acreage disclosure on page 226 of Amendment No. 1
states the
      table includes the Company   s acreage as of December 31, 2024 rather
than as of
      December 31, 2023. Also, under the table item    Exploration Permits
the total net
      undeveloped acreage shown, as of December 31, 2023, is 1,623,209 acres
rather than
      682,802 acres. Please review and revise these items as necessary to
remove any
      inconsistency.
Reserve Information, page F-77

14.   After review of Amendment No. 1, it appears the table on page F-77
showing the
      reconciliation of changes in total proved developed and undeveloped
reserves, as of
      December 31, 2023 and December 31, 2022, and the table on page 225
showing
      the reconciliation of changes in proved undeveloped reserves, as of
December 31,
      2023, were unchanged from your prior submission. We re-issue prior
comment 50.

      Also, please expand each of these disclosures to provide detailed
explanations of the
      volume changes related to each contributing factor, both positive and
negative, so the
      entire volume change during each year is explained.
General

15.   We note you disclose that SPAC entered into an advisory services
agreement with
      Rowdeston Capital Corp., an entity owned by Thomas J. Loch, in April
2024. Please
      revise to clarify Rowdeston's role and any services rendered in advising
SPAC. In
      addition, please revise your conflicts of interest disclosure on your
cover page,
      prospectus summary, and throughout your proxy statement/prospectus to
address any
      related conflicts since Thomas J. Lock is the father of Aston Loch,
SPAC's Chief
      Operating Officer and Secretary and a control person of the Sponsor, and
the fees
      payable thereunder. Refer to Items 1603(b), 1604(a)(4), and 1604(b)(3) of
Regulation
      S-K.
16.   We note your revised disclosure in response to prior comment 6. However,
your risk
      factor disclosure on page 104 continues to disclose that December 17,
2025 would be
      the 36-month anniversary of the effectiveness of your initial public
offering. Please
      advise or revise. In addition, we note you disclose that SPAC may seek to
extend the
      time it has to complete its initial business combination beyond such
36-month period
      and that the current deadline set forth in the SPAC Articles of
Association for SPAC
      to complete its initial business combination is June 17, 2025. Please
expand your
      disclosure to discuss that Nasdaq Rule 5815 was amended effective October
7, 2024
      to provide for the immediate suspension and delisting upon issuance of a
delisting
      determination letter for failure to meet the requirement in Nasdaq Rule
IM 5101-2(b)
      to complete one or more business combinations within 36 months of the
date of
      effectiveness of its IPO registration statement. Please also revise to
state that your
      securities will face immediate suspension and delisting action once you
receive a
 October 25, 2024
Page 6

       delisting determination letter from Nasdaq after the 36-month window
ends on
       December 14, 2024 and disclose the risks of non-compliance with this
rule, including
       that under the new framework, Nasdaq may only reverse the determination
if it finds
       it made a factual error applying the applicable rule. Disclose the
consequences of any
       such suspension or delisting, including that your stock may be
determined to be a
       penny stock and the consequences of that designation, that you may no
longer be
       attractive as a merger partner if you are no longer listed on an
exchange, any potential
       impact on your ability to complete an initial business combination, any
impact on the
       market for your securities including demand and overall liquidity for
your securities,
       and any impact on securities holders due to your securities no longer
being considered
          covered securities.
        Please contact Robert Babula, Staff Accountant, at 202-551-3339 or Gus
Rodriguez,
Staff Accountant, at 202-551-3752 if you have questions regarding comments on
the
financial statements and related matters. You may contact John Hodgin,
Petroleum Engineer,
at 202-551-3699, or Sandra Wall, Petroleum Engineer, at 202-551-4727 with
questions about
engineering comments. Please contact Irene Barberena-Meissner, Staff Attorney,
at 202-551-
6548 or Karina Dorin, Staff Attorney, at 202-551-3763 with any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Energy &
Transportation
cc:   Adam Namoury, Esq.
      Stephen Grant, Esq.