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                            February 14, 2023

       Claudius Tsang
       Director and Chief Executive Officer
       A Paradigm Acquisition Corp.
       Level 39, Marina Bay Financial Centre
       Tower 2, 10 Marina Boulevard
       Singapore 018983

                                                        Re: A Paradigm
Acquisition Corp.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted January
17, 2023
                                                            CIK No. 0001956439

       Dear Claudius Tsang:

              We have reviewed your draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form S-1 submitted January 17, 2023

       The Offering, page 34

   1.                                                   Where you state on page
34 that stockholders may seek to redeem their shares, regardless
                                                        of whether they vote
for or against the proposed business combination, please clarify
                                                        whether stockholders
may elect to redeem if they abstain from voting on the proposed
                                                        business combination.
 Claudius Tsang
FirstName
A ParadigmLastNameClaudius
            Acquisition Corp. Tsang
Comapany14,
February  NameA
            2023 Paradigm Acquisition Corp.
February
Page 2 14, 2023 Page 2
FirstName LastName
Risk Factors
If we seek shareholder approval of our initial business combination, page 54

2.       We note that your sponsor, officers, directors and affiliates may
purchase shares from
         public stockholders for the purpose of voting those shares in favor of
a proposed business
         combination, thereby increasing the likelihood of the completion of
the combination.
         Please explain how such purchases would comply with the requirements
of Rule 14e-5
         under the Exchange Act. Refer to Tender Offer Rules and Schedules
Compliance and
         Disclosure Interpretation 166.01 for guidance.
We may redeem your unexpired warrants prior to their exercise..., page 81

3.       We note your ability to redeem outstanding warrants at any time after
they become
         exercisable and prior to their expiration, at a price of $1.00 per
warrant if certain
         conditions are met. However, on page 22, you disclosed that you may
redeem the
         outstanding warrants (excluding the private placement warrants) at a
price of $0.01 per
         warrant. Please advise or reconcile the discrepancy.
We may issue our shares to investors in connection with our initial business
combination..., page
82

4.       We note that potential PIPE transactions are meant to enable you to
provide sufficient
         liquidity to the post-business combination entity. Clearly disclose
their impact to you and
         investors, including that the arrangements result in costs particular
to the de-SPAC
         process that would not be anticipated in a traditional IPO. If true,
disclose that the
         agreements are intended to ensure a return on investment to the
investor in return for
         funds facilitating the sponsor   s completion of the business
combination or providing
         sufficient liquidity.
We may not be able to complete an initial business combination with a U.S.
target company...,
page 103

5.       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.
Enforceability of Civil Liabilities, page 117

6.       We note disclosure on the difficulties related to civil enforcement
since your directors and
         officers are nationals or residents of jurisdictions other than the
United States, and all or a
         substantial portion of their assets are located outside the United
States. Please expand your
         disclosure to identify each officer and/or director located in China
or Hong Kong.
Capitalization, page 125

7.       It appears you intend to account for your private warrants as equity.
Please provide us
         with your analysis under ASC 815-40 to support your accounting
treatment for these
 Claudius Tsang
A Paradigm Acquisition Corp.
February 14, 2023
Page 3
      warrants. As part of your analysis, please address whether there are any
terms or
      provisions in the warrant agreement that provide for potential changes to
the settlement
      amounts that are dependent upon the characteristics of the holder of the
warrant, and if so,
      how you analyzed those provisions in accordance with the guidance in ASC
815-40. Your
      response should address, but not be limited to, your disclosure that
"[i]f the private
      placement warrants are held by someone other than our sponsor, Cantor or
their permitted
      transferees, the placement warrants will be redeemable by us and
exercisable by such
      holders on the same basis as the warrants included in the units being
sold in this offering."
Report of Independent Registered Public Accounting Firm, page F-2

8.    Please ensure that your auditor's report is dated in your next amendment.
Statement of Cash Flows, page F-6

9.    Please tell us why proceeds from the promissory note to a related party
of $2,939 are
      recorded on your statement of cash flows when the balance sheet and Note
5 indicate that
      the loan amount was $8,597 as of December 31, 20222.
       You may contact Eric McPhee at 202-551-3693 or Kristina Marrone at
202-551-3429 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Kibum Park at 202-551-6836 or Jeffrey Gabor at 202-551-2544 with any
other questions.



                                                            Sincerely,
FirstName LastNameClaudius Tsang
                                                            Division of
Corporation Finance
Comapany NameA Paradigm Acquisition Corp.
                                                            Office of Real
Estate & Construction
February 14, 2023 Page 3
cc:       Jeffrey C. Cohen
FirstName LastName