United States securities and exchange commission logo





                        April 12, 2023

       CERTIFIED MAIL
       RETURN RECEIPT REQUESTED

       James Francis
       Chief Executive Officer
       ESH Acquisition Corp.
       228 Park Ave S, Suite 89898
       New York, New York 10003-1502

                                                        Re: ESH Acquisition
Corp.
                                                            Registration
Statement on Form S-1
                                                            Filed May 26, 2022
                                                            File No. 333-265226

       Dear James Francis:

               It has been more than nine months since you filed this
registration statement and it is now
       out of date. Within 30 days from the date of this letter, you should
either:

                                                  amend it to comply with the
applicable requirements of the Securities Act of 1933, the rules
                                                and regulations under the Act,
and the requirements of the form; or

                                                  file a request for
withdrawal.



              If you requested confidential treatment for portions of any
exhibits to your registration
       statement and you request withdrawal of that registration statement,
please submit a concurrent
       request for withdrawal of your application for confidential treatment.

              If you do not amend the registration statement or file a request
for withdrawal (or provide
       us with a satisfactory explanation of why you have not done either)
within 30 days, we may enter
       an order declaring the registration statement abandoned under rule 479
of the Act.
 James Francis
ESH Acquisition Corp.
April 12, 2023
Page 2

      Please contact Catherine De Lorenzo at 202-551-4079 or Ruairi Regan at
202-551-
3269 with any questions.



FirstName LastNameJames Francis                         Sincerely,
Comapany NameESH Acquisition Corp.
                                                        Division of Corporation
Finance
April 12, 2023 Page 2                                   Office of Real Estate &
Construction
FirstName LastName