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                           October 26, 2021

       Stephen Fitzpatrick
       Chief Executive Officer
       Vertical Aerospace Ltd.
       140-142 Kensington Church Street
       London, W8 4BN
       United Kingdom

                                                        Re: Vertical Aerospace
Ltd.
                                                            Amendment No. 3 to
Registration Statement on Form F-4
                                                            Filed October 8,
2021
                                                            File No. 333-257785

       Dear Mr. Fitzpatrick:

             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.
Unless we note
       otherwise, our references to prior comments are to comments in our
October 5, 2021 letter.

       Amendment No. 3 to Registration Statement on Form F-4 filed October 8,
2021

       Questions and Answers about the Proposed Transactions
       Q. What are the possible sources and the extent of dilution that
Broadstone's shareholders..., page
       24

   1.                                                   It appears to us that
the total shares in the    assuming maximum redemption    column of
                                                        your table should read
193,833,409. Please revise your disclosure accordingly.
 Stephen Fitzpatrick
FirstName  LastNameStephen  Fitzpatrick
Vertical Aerospace  Ltd.
Comapany
October  26,NameVertical
             2021        Aerospace Ltd.
October
Page 2 26, 2021 Page 2
FirstName LastName
Notes to the Unaudited Pro Forma Combined Financial Statements
Note 4 - Net Loss per Share, page 178

2.       Please revise your disclosure to address the reason that the shares to
be received by the
         Vertical Option Holders have been excluded from calculation of pro
forma EPS.
         Additionally, please revise your footnote to quantify any outstanding
options or warrants
         that have been excluded from the calculations of pro forma diluted
loss per share amounts
         because they are anti-dilutive.
Vertical's Management's Discussion and Analysis of Financial Condition and
Results of
Operations
Liquidity and Capital Resources, page 229

3.       Please quantify and more fully discuss Vertical   s current and
long-term liquidity
         requirements and priorities, including potential changes in those
priorities based on the
         impact of changes in the amount of cash available to the
post-combination entity due to
         the amount of cash redemptions.
       You may contact Dale Welcome at 202-551-3865 or Kevin Stertzel at
202-551-3723 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Thomas Jones at 202-551-3602 or Erin Purnell at 202-551-3454 with any
other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Manufacturing
cc:      Robbie McLaren, Esq.