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                          March 22, 2022

       Yoann Delwarde
       Chief Executive Officer
       Embrace Change Acquisition Corp.
       5186 Carroll Canyon Rd
       San Diego, CA 92121

                                                        Re: Embrace Change
Acquisition Corp.
                                                            Amendment No. 5
Registration Statement on Form S-1
                                                            Filed on March 14,
2022
                                                            File No. 333-258221

       Dear Mr. Delwarde:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comment. 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 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 the comment, we may have additional comments.

       Form S-1/A filed March 14, 2022

       General, page 70

   1.                                                   We note your response
to prior comment 2 and the statement on page 70 that you engaged
                                                        the services of ARC
Group Limited to provide financial advisory services to you "in
                                                        connection with this
offering." Please file the agreement between ARC and the sponsor
                                                        and revise page 70 to
further clarify the services to be provided by ARC in connection
                                                        with the offering
and/or identification and consummation of an initial business
                                                        combination.
               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.
 Yoann Delwarde
Embrace Change Acquisition Corp.
March 22, 2022
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Eric McPhee at 202-551-3693 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Victor Rivera Melendez at 202-551-4182 or James Lopez at 202-551-3536
with any
other questions.



                                                           Sincerely,
FirstName LastNameYoann Delwarde
                                                           Division of
Corporation Finance
Comapany NameEmbrace Change Acquisition Corp.
                                                           Office of Real
Estate & Construction
March 22, 2022 Page 2
cc:       Giovanni Caruso
FirstName LastName