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                               September 30, 2022

       Jonathan Intrater
       Chief Executive Officer
       Mana Capital Acquisition Corp.
       8 The Green, Suite 12490
       Dover, DE 19901

                                                        Re: Mana Capital
Acquisition Corp.
                                                            Amendment No. 3 to
Registration Statement on Form S-4
                                                            Filed September 15,
2022
                                                            File No. 333-265308

       Dear Mr. Intrater:

             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
September 8, 2022 letter.

       Amendment No. 3 to Registration Statement on Form S-4

       General

   1.                                                   With a view toward
disclosure, please tell us whether your sponsor is, is controlled by, or
                                                        has substantial ties
with a non-U.S. person. Please also tell us whether anyone or any
                                                        entity associated with
or otherwise involved in the transaction, is, is controlled by, or has
                                                        substantial ties with a
non-U.S. person. If so, also include risk factor disclosure that
                                                        addresses how this fact
could impact your ability to complete your initial business
                                                        combination. For
instance, discuss the risk to investors that you may not be able to
                                                        complete an initial
business combination with a U.S. target company should the
                                                        transaction be subject
to review by a U.S. government entity, such as the Committee on
                                                        Foreign Investment in
the United States (CFIUS), or ultimately prohibited. Further,
 Jonathan Intrater
Mana Capital Acquisition Corp.
September 30, 2022
Page 2
      disclose that the time necessary for government review of the transaction
or a decision to
      prohibit the transaction could prevent you from completing an initial
business
      combination and require you to liquidate. Disclose the consequences of
liquidation to
      investors, such as the losses of the investment opportunity in a target
company, any price
      appreciation in the combined company, and the warrants, which would
expire worthless.
       You may contact Christine Torney at 202-551-3652 or Brian Cascio at
202-551-3676 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Doris Stacey Gama at 202-551-3188 or Joe McCann at 202-551-6262 with
any other
questions.



                                                           Sincerely,
FirstName LastNameJonathan Intrater
                                                           Division of
Corporation Finance
Comapany NameMana Capital Acquisition Corp.
                                                           Office of Life
Sciences
September 30, 2022 Page 2
cc:       Jie Chengying Xiu, Esq.
FirstName LastName