November 5, 2024

Michael B. Hoffman
Chief Executive Officer
Translational Development Acquisition Corp.
c/o 151 W. 42nd Street, 49th Floor
New York, NY10036

       Re: Translational Development Acquisition Corp.
           Registration Statement on Form S-1
           Filed October 22, 2024
           File No. 333-282763
Dear Michael B. Hoffman:

       We have reviewed your 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 8,
2024 letter.

Registration Statement on Form S-1 filed October 22, 2024
Cover Page

1.     We note your response to prior comment 2. Please also describe the
private placement
       warrants issuance to your sponsor and the price paid for the private
placement
       warrants where you discuss material dilution to your public
shareholders.
General

2.     We note your response to prior comment 11. We are considering your
response and
       may have further comment.
 November 5, 2024
Page 2
3.     We note your disclosure regarding the assignment and novation agreement
pursuant to
       which Stone Capital Partners LLC's rights, obligations and liabilities
under the
       previous subscription agreement were transferred to and assumed by TDAC
Partners
       LLC and TDAC Partners LLC became your current sponsor. We also note
       that Michael B. Hoffman is the managing member and owns 100% of the
economic
       interests in both entities. Please disclose the purpose of the
assignment and novation
       agreement.

        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.

       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.

       Please contact Frank Knapp at 202-551-3805 or Jennifer Monick at
202-551-3295 if
you have questions regarding the financial statements and related matters.
Please contact
Ronald (Ron) E. Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713 with
any
other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate & Construction
cc:   William N. Haddad