July 11, 2024

Adam Stone
Chief Executive Officer
Aja Holdco, Inc.
51 Astor Place, 10th Floor
New York, New York 10003

       Re: Aja Holdco, Inc.
           Amendment No. 2 to Registration Statement on Form S-4
           Filed June 25, 2024
           File No. 333-278811
Dear Adam Stone:

     We have reviewed your amended 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 May 30, 2024 letter.

Amendment No. 2 to Registration Statement on Form S-4
ARYA's Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Results of Operations, page 232

1.     Please provide a discussion and analysis of ARYA   s fiscal year 2023 to
fiscal year 2022
       results of operations. Refer to Item 14(h) of Form S-4 and Item 303 of
Regulation S-K for
       guidance.
Business of Adagio and Certain Information About Adagio
Ventricular Tachyarrhythmias, page 241

2.     We note your reference in the first paragraph on page 243 to "a catheter
market that is
       currently estimated to be $0.3 billion." On page 6 of the investor
presentation, dated June
       2024, which was included as Exhibit 99.1 to the Current Report on Form
8-K filed by
 July 11, 2024
Page 2

       ARYA Sciences Acquisition Corp IV on June 11, 2024, you refer to the
"~$3 billion
       catheter market." Please tell us if the estimated size of the catheter
market is $0.3 billion
       or $3 billion and revise your disclosure for consistency as applicable.
Description of New Adagio Securities
Exclusive Jurisdiction of Certain Actions, page 337

3.     We note that Article VIII of the Form of Certificate of Incorporation of
New Adagio and
       Section 9.5 of the Form of Bylaws of New Adagio each contain forum
selection clauses.
       Please clarify which forum selection provision will be in effect after
the closing. Disclose
       whether the forum selection provision in effect after the closing
applies to actions arising
       under the Securities Act or Exchange Act. If so, please also state that
there is uncertainty
       as to whether a court would enforce such provision. If the provision
applies to Securities
       Act claims, please also state that investors cannot waive compliance
with the federal
       securities laws and the rules and regulations thereunder. In that
regard, we note that
       Section 22 of the Securities Act creates concurrent jurisdiction for
federal and state courts
       over all suits brought to enforce any duty or liability created by the
Securities Act or the
       rules and regulations thereunder. If this provision does not apply to
actions arising under
       the Securities Act or Exchange Act, please also ensure that the
exclusive forum provision
       in the governing documents states this clearly, or tell us how you will
inform investors in
       future filings that the provision does not apply to any actions arising
under the Securities
       Act or Exchange Act.
       Please contact Tracey Houser at 202-551-3736 or Li Xiao at 202-551-4391
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Conlon Danberg at 202-551-4466 or Tonya Aldave at 202-551-3601 with any other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Industrial Applications and
                                                              Services
cc:   Peter Seligson, Esq.