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                              October 19, 2021

       Sten Gustafson
       Chief Executive Officer
       Pyrophyte Acquisition Corp.
       3262 Westheimer Road
       Suite 706
       Houston, TX 77098

                                                        Re: Pyrophyte
Acquisition Corp.
                                                            Registration
Statement on Form S-1
                                                            Filed October 5,
2021
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed October 14,
2021
                                                            File No. 333-260041

       Dear Mr. Gustafson:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, 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 comments apply 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 these comments, we may have additional comments.

       Amendment No. 1 to Registration Statement on Form S-1 filed October 14,
2021

       Exhibits

   1.                                                   We note that the forum
selection provision in your amended and restated memorandum
                                                        and articles of
association identifies the courts of the Cayman Islands as the exclusive
                                                        forum for certain
litigation, including any    derivative action.    Please disclose whether this
                                                        provision applies to
actions arising under the Securities Act or Exchange Act. In that
                                                        regard, we note that
Section 27 of the Exchange Act creates exclusive federal jurisdiction
                                                        over all suits brought
to enforce any duty or liability created by the Exchange Act or the
                                                        rules and regulations
thereunder, and Section 22 of the Securities Act creates concurrent
 Sten Gustafson
Pyrophyte Acquisition Corp.
October 19, 2021
Page 2
       jurisdiction for federal and state courts over all suits brought to
enforce any duty or
       liability created by the Securities Act or the rules and regulations
thereunder. If the
       provision applies to Securities Act claims, please also revise your
prospectus to state that
       there is uncertainty as to whether a court would enforce such provision
and that investors
       cannot waive compliance with the federal securities laws and the rules
and regulations
       thereunder. If this provision does not apply to actions arising under
the Securities Act or
       Exchange Act, please also ensure that the exclusive forum provision in
the amended and
       restated memorandum and articles of association states this clearly.
        You may contact Sondra Snyder, Staff Accountant, at (202) 551-3332 or
Gus Rodriguez,
Accounting Branch Chief, at (202) 551-3752 if you have questions regarding
comments on the
financial statements and related matters. Please contact Liz Packebusch, Staff
Attorney, at (202)
551-8749 or Loan Lauren Nguyen, Legal Branch Chief, at (202) 551-3642 with any
other
questions.



                                                             Sincerely,
FirstName LastNameSten Gustafson
                                                             Division of
Corporation Finance
Comapany NamePyrophyte Acquisition Corp.
                                                             Office of Energy &
Transportation
October 19, 2021 Page 2
cc:       Elliott M. Smith
FirstName LastName