United States securities and exchange commission logo





                             September 6, 2023

       Nathan P. Pereira
       Chief Executive Officer
       Unite Acquisition 2 Corp.
       12 E. 49th Street, 11th Floor
       New York, NY 10017

                                                        Re: Unite Acquisition 2
Corp.
                                                            Registration
Statement on Form 10-12G
                                                            Filed August 10,
2023
                                                            File No. 000-56581

       Dear Nathan P. Pereira:

              We have reviewed your filing 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-12G filed August 10, 2023

       Business of the Issuer, page 1

   1.                                                   Please reconcile your
disclosure in the fourth paragraph that there have been no    specific
                                                        discussions with the
disclosure in the first paragraph on page 7 that your sole officer and
                                                        director has not had
any preliminary contact or discussions with any representative of any
                                                        other entity regarding
a business combination with you.
   2.                                                   We note your statements
on page 3 that your sole officer and director is "currently
                                                        involved with two other
blank check companies and may become associated with
                                                        additional blank check
companies at any time in the future," and that he is "employed on a
                                                        full-time basis by
other companies." Please revise to state how many companies your sole
                                                        officer and director is
employed on a full-time basis. Also explain how he will allocate
                                                        his time if there is a
concurrent acquisition opportunity for any of the other blank check
                                                        companies with which he
is involved.
 Nathan P. Pereira
FirstName LastNameNathan
Unite Acquisition 2 Corp. P. Pereira
Comapany 6,
September NameUnite
             2023     Acquisition 2 Corp.
September
Page 2    6, 2023 Page 2
FirstName LastName
3.       We note your disclosure in Item 9 on page 11 that your common stock is
not trading on
         any stock exchange. Where you discuss your competition to complete a
business
         acquisition, please expand to address how the lack of trading on an
exchange may impact
         your likelihood of success in finding a target company and completing
a business
         combination.
Management's Discussion & Analysis, page 5

4.       We note your first sentence on page 7 that your sole officer and
director has not had any
         preliminary contact or discussions with any representative of any
other entity regarding a
         business combination with you. Given your relationship with Lucius
Partners and
         your statement that you contemplate Lucius Partners may introduce
business combination
         opportunities to you, please revise to confirm that Lucius Partners
has not had, on your
         behalf, any such contact or discussions with other entities regarding
a business
         combination with you.
5.       We note your statement that your management believes there are
opportunities for a
         business combination with firms seeking the perceived benefits of
becoming a publicly
         traded corporation. Please revise your disclosure to state clearly how
a private operating
         company would benefit by completing a business combination with you
rather than by
         filing its own Exchange Act registration statement, given the
information about the target
         company that you state will be filed in a Form 8-K at the time of the
business
         combination.
Item 5. Directors and Executive Officers, page 8

6.       In light of the statement on page 3 that Mr. Pereira is employed on a
full-time basis by
         other companies, please revise to ensure that you have disclosed all
principal occupations
         and employment during the past five years, including the name and
principal business of
         any corporation or other organization in which such occupations and
employment were
         carried on and whether such corporation or organization is a parent,
subsidiary or other
         affiliate of the registrant. Refer to Item 401(e)(1) of Regulation
S-K.
Item 6. Executive Compensation
Summary Compensation Table, page 9

7.       We note your disclosure that your sole officer and director has not
received any cash or
         other compensation since inception. Please clarify whether he has
earned any
         compensation.
8.       We note your disclosure that there are currently no understandings or
agreements
         regarding compensation your management will receive after a business
combination.
         Please expand your disclosure to clarify whether there are any
arrangements, whether
         written or unwritten, under which your sole officer and director will
receive any
         compensation prior to a business combination, and if so, please
describe the material
         terms. Please provide similar clarification and disclosure of the
material terms of any
 Nathan P. Pereira
Unite Acquisition 2 Corp.
September 6, 2023
Page 3
      arrangements, whether written or unwritten, pursuant to which the sole
officer and
      director would receive any potential payments upon termination or change
in
      control. Refer to Item 402(o) and (q) of Regulation S-K.
        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.

       You may contact Frank Knapp at 202-551-3805 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Mary Beth Breslin at 202-551-3625 with any other questions.



                                                           Sincerely,
FirstName LastNameNathan P. Pereira
                                                           Division of
Corporation Finance
Comapany NameUnite Acquisition 2 Corp.
                                                           Office of Real
Estate & Construction
September 6, 2023 Page 3
cc:       Barrett DiPaolo
FirstName LastName