October 15, 2024

Eli Baker
Chief Executive Officer
Bold Eagle Acquisition Corp.
955 Fifth Avenue
New York, NY 10075

       Re: Bold Eagle Acquisition Corp.
           Amendment No. 2 to Registration Statement on Form S-1
           Filed October 11, 2024
           File No. 333-282268
Dear Eli Baker:

     We have reviewed your amended registration statement and have the
following
comments.

        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 October 11,
2024, letter.

Amendment No. 2 to Registration Statement on Form S-1
General

1.     We note your response to prior comment 1. As previously requested,
please revise
       throughout the prospectus to provide the total amount and percentage of
ordinary
       shares that will be held by the sponsor upon completion of this
offering, including the
       private placement shares.
2.     We note that in the event you enter into a business combination with a
company with
       a pro forma equity value in excess of $3 billion, pursuant to the letter
agreement you
       would restructure the founder shares such that the fully vested founder
shares held by
       your sponsor immediately upon the consummation of such business
combination will
       represent approximately 1% of such pro forma equity value of the pro
forma
       combined company. The conversion ratio and the anti-dilution adjustment
as set forth
 October 15, 2024
Page 2

       in the memorandum and articles of association do not contemplate such
adjustment.
       Please disclose how these two provisions would be applied to the founder
shares in
       the event of a business combination with a company with a pro forma
equity value in
       excess of $3 billion. In addition, please provide clear disclosure each
time you
       reference this provision of the letter agreement to clearly reflect the
ease with which
       such provision may be amended at any time, as opposed to the conversion
provision
       in the memorandum and articles of association, which would require
shareholder
       approval to amend.
       Please contact Peter McPhun at 202-551-3581 or Wilson Lee at
202-551-3468 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Stacie Gorman at 202-551-3585 or Pam Howell at 202-551-3357 with any
other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate & Construction
cc:   Daniel Nussen, Esq.