November 19, 2024

Claudius Tsang
Chief Executive Officer, Chief Financial Officer and Chairman
A Paradigm Acquisition Corp.
The Sun   s Group Center, 29th Floor
200 Gloucester Road
Wan Chai, Hong Kong

       Re: A Paradigm Acquisition Corp.
           Amendment No. 2 to Draft Registration Statement on Form S-1
           Submitted October 23, 2024
           CIK No. 0001956439
Dear Claudius Tsang:

     We have reviewed your amended draft registration statement and have the
following
comments.

       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 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our March 27, 2023 letter.

Amendment No. 2 to Draft Registration Statement on Form S-1 filed October 23,
2024
Cover Page

1.     We note the indirect purchase of non-voting interests by the non-voting
sponsors
       investors. Please revise to clarify whether the indirect purchase of
private placement
       warrants by non-voting sponsors investors is conditioned upon their
purchase of units
       in the offering, or vice versa. Also, please revise to disclose the
maximum percentage
       of the offering that could be purchased in the aggregate by the
non-voting sponsors
       investors.
 November 19, 2024
Page 2

Summary
Our Founder's Experience, page 3

2.     With respect to the de-SPAC transactions with MultiMetaVerse and
NewGenIVF,
       please revise to disclose additional information regarding the de-SPAC
transactions,
       including the financing needed for the transactions and the level of
redemptions. With
       respect to A SPAC II and III, please revise to highlight any potential
target business
       industry overlap with yours, A SPAC II's original termination date, the
new extended
       termination date, and the amount remaining in the trust account. In
addition, revise
       your disclosure here to discuss the high level of competition you may
face in pursuing
       business combination transaction candidates and also explain that the
competition
       may negatively impact the acquisition terms you are able to negotiate.
Initial Business Combination, page 6

3.     We note your disclosure that you will obtain an opinion from an
independent
       accounting firm or independent investment banking firm if the target is
affiliated with
       your sponsor, officers, or directors. Please revise your disclosure to
clarify, if true,
       that a target business affiliated with a non-voting sponsor investors
would not be
       considered an affiliated entity.
Sponsor Information, page 14

4.     Please revise to clarify, as of the most recent practicable date, the
persons who have
       direct and indirect material interests in the SPAC sponsor, as well as
the nature and
       amount of their interests. See Item 1603(a)(7) of Regulation S-K.
5.     We note the disclosure here and elsewhere that in order to facilitate
your initial
       business combination or for any other reason determined by your sponsor
in its sole
       discretion, your sponsor may surrender or forfeit, transfer or exchange
your founder
       shares, private placement warrants or any of your other securities,
including for no
       consideration, as well as subject any such securities to earn-outs or
other restrictions,
       or otherwise amend the terms of any such securities or enter into any
other
       arrangements with respect to any such securities. Please add risk factor
disclosure
       about risks that may arise from the sponsor having the ability to remove
itself as your
       sponsor before identifying a business combination, including through the
       unconditional ability to transfer the founder shares or otherwise.
The Offering, page 20

6.     Please revise each subsection where you discuss voting requirements, and
elsewhere
       as appropriate, to clarify the potential impact of non-voting sponsor
investors on
       approving a business combination. In this regard, we note the disclosure
on page
       88 that you would not need any additional public shares sold in this
offering to be
       voted in favor of your initial business combination in the event that
the non-voting
       sponsor investors purchase the full amount of units.
 November 19, 2024
Page 3
Anticipated expenses and funding sources, page 32

7.     Please revise this section or include a new section within the Summary
under an
       appropriate subsection to provide a more comprehensive discussion
regarding whether
       you have any plans to seek additional financing and how such financings
may impact
       unaffiliated security holders, as required by Item 1602(b)(5) of
Regulation S-K.
Comparison of This Offering to Those of Blank Check Companies Subject to Rule
419
Election to remain an investor, page 181

8.     We note your disclosure that if shareholder approval is sought for the
initial business
       combination, you expect that a final proxy statement would be mailed to
shareholders
       at least 10 days prior to the shareholder vote. Please revise to
reconcile this disclosure
       with Rule 14a-6, which requires that the proxy statement of a special
purpose
       acquisition company and relating to a de-SPAC transaction must be
distributed to
       security holders no later than the lesser of 20 calendar days prior to
the shareholder
       meeting date or the maximum number of days permitted for disseminating
the proxy
       statement under the applicable laws of the jurisdiction of incorporation
or
       organization.
Principal Shareholders, page 199

9.     Please revise the table to include the correct name of the sponsor.
Signatures, page II-5

10.    Please identify the principal accounting officer or controller. In
addition, please revise
       your signatures to include at least a majority of the board of directors
on the effective
       date, or, if your director nominees will become directors after
effectiveness or upon
       closing, please revise to specifically clarify. See Instructions to
Signatures for Form
       S-1.

       Please contact Eric McPhee at 202-551-3693 or Kristina Marrone at
202-551-3429 if
you have questions regarding the financial statements and related matters.
Please contact
Ronald (Ron) E. Alper at 202-551-3329 or Jeffrey Gabor at 202-551-2544 with any
other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Real
Estate & Construction
cc:   Jeffrey C. Cohen