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                              December 14, 2023

       Al Lopez
       Chief Executive Officer
       IB Acquisition Corp.
       2500 N Military Trail, Suite 160-A
       Boca Raton FL 33431

                                                        Re: IB Acquisition
Corp.
                                                            Registration
Statement on Form S-1
                                                            Filed November 17,
2023
                                                            File No. 333-275650

       Dear Al Lopez:

                                                        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.

       Registration Statement on Form S-1

       Cover Page

   1.                                                   We note your disclosure
that you will have 18 months from the closing of the initial
                                                        public offering to
consummate your initial business combination. Please clarify, if true,
                                                        that you may amend your
organizational documents to extend your business combination
                                                        deadline. If there are
reasons why you cannot or will not seek shareholder approval to
                                                        extend such deadline,
please state so. Please add similar clarification elsewhere in your
                                                        filing where you
describe the deadline.
   2.                                                   We note your disclosure
on page 8 that the board could determine to modify your bylaws
                                                        to "reduce the number
of shares required to be present at a meeting of our stockholders"
                                                        and that this would
result in it being significantly more likely that your initial business
                                                        combination would be
approved. Please revise the cover page to reflect this
                                                        option. Further, we
note your disclosure that "if only the minimum number of
                                                        stockholders required
to be present ... are present at such meeting, in addition to the
                                                        founder shares and
private placement shares held by our sponsor and the 350,000
 Al Lopez
FirstName LastNameAl
IB Acquisition Corp. Lopez
Comapany14,
December   NameIB
              2023 Acquisition Corp.
December
Page 2    14, 2023 Page 2
FirstName LastName
         Representative shares held by I-Bankers, we would not need any of the
10,000,000 public
         shares to be voted in favor of our initial business combination in
order to have such
         transaction approved." Please also revise the cover to reflect this
disclosure.
The Offering
Redemption rights for public stockholders . . ., page 11

3.       We note your statement that your public shareholders will have the
opportunity to redeem
         their shares upon the completion of your business combination. Please
revise here, and
         elsewhere, to disclose whether the shareholders will be permitted to
redeem their shares
         regardless of whether they abstain, vote for, or against, the proposed
transaction or
         whether they must vote against it.
Conflicts of Interest, page 16

4.       Please expand your discussion regarding how certain of your sponsor's
members are
         associated with I-Bankers to also disclose the M&A fee and finder fee.
Risk Factors
We may engage our underwriters or one of their respective affiliates..., page
20

5.       Please revise to reconcile your disclosure here, which states that you
"may" engage your
         underwriter or their affiliates to provide additional services such as
arranging debt
         financing transactions, with your disclosures elsewhere, including
your disclosure on page
         93 that you have already engaged I-Bankers to assist you with various
matters, including
         to introduce you to potential investors. You also state that you will
pay I-Bankers a finder
         fee of 1% of the consideration issued to the target. Please revise
your disclosures
         throughout, including your discussions regarding conflicts of
interest, to also highlight this
         fee. We also note your disclosure that fees paid to your underwriter
or its affiliates will be
         based on arm's length negotiations. Given the significant relationship
between you and
         your underwriter, please revise to describe the negotiations resulting
in these fees, and
         explain why you consider such negotiations were conducted on an arm's
length basis.
         State whether Ms. Panigone was involved with such negotiations (as we
note your
         disclosure of her former experience with I-Bankers), and explain how
any future
         negotiations will be conducted on an arm's length basis. Additionally,
please expand the
         risk factor to disclose the risks associated with negotiating with
your affiliated entities.
We may be unable to obtain additional financing to complete our initial
business combination. .
.., page 32

6.       Please revise to reconcile your statement here that you believe the
net proceeds of this
         offering and the sale of the private placement units will be
sufficient to allow you to
         complete your business combination, with your disclosures elsewhere
stating that you
         anticipate targeting a business with an enterprise value of at least
$500 million. Also,
         clearly disclose the impact of any future financings to you and
investors. To the extent
 Al Lopez
FirstName LastNameAl
IB Acquisition Corp. Lopez
Comapany14,
December   NameIB
              2023 Acquisition Corp.
December
Page 3    14, 2023 Page 3
FirstName LastName
         you may utilize PIPE transactions, 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. Please also
         disclose that these arrangements result in costs particular to the
de-SPAC process that
         would not be anticipated in a traditional IPO. Additionally, clarify
how you expect to pay
         for the M&A fee and the finder fee.
Provisions in our amended and restated articles of incorporation and Nevada
law..., page 46

7.       Please revise your introductory paragraph to highlight the forum
provision discussed in
         the risk factor. Additionally, please expand to address the forum
provision applicable to
         your rights, as discussed on page 97.
Management, page 83

8.       Please provide disclosure regarding Feng Xiangkun's experience
pursuant to Items 401(c)
         and (e) of Regulation S-K or otherwise advise. In addition, we note
your statements that
         each of your officers and directors are members of your sponsor, that
Ms. Panigone
         formerly worked at I-Bankers Direct, and that certain members of your
sponsor are
         "associated persons" of I-Bankers and that these members own
approximately over 52%
         of your sponsor. Please revise to clarify when her experience with
I-Bankers occurred.
Principal Stockholders, page 90

9.       We note your statement that Shelley Leonard is the manager of your
sponsor. Please
         revise to clarify whether she exercises the voting and/or dispositive
control with respect to
         the securities owned by I-B Good Works 4, LLC, and if not, please
revise to disclose such
         natural person(s).
        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.
 Al Lopez
IB Acquisition Corp.
December 14, 2023
Page 4

       Please contact Jeffrey Lewis at 202-551-6216 or Wilson Lee at
202-551-3468 if you have
questions regarding comments on the financial statements and related matters.
Please contact
Stacie Gorman at 202-551-3585 or Dorrie Yale at 202-551-8776 with any other
questions.



                                                         Sincerely,
FirstName LastNameAl Lopez
                                                         Division of
Corporation Finance
Comapany NameIB Acquisition Corp.
                                                         Office of Real Estate
& Construction
December 14, 2023 Page 4
cc:       Cavas S. Pavri, Esq.
FirstName LastName