March 6, 2025

Peter Ort
Principal Executive Officer
Digital Asset Acquisition Corp.
174 Nassau Street, Suite 2100
Princeton, NJ 08542

        Re: Digital Asset Acquisition Corp.
            Registration Statement on Form S-1
            Filed February 7, 2025
            File No. 333-284776
Dear Peter Ort:

       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 filed February 7, 2025
Cover Page

1.     Please clearly state that there may be actual or potential material
conflicts of interest
       between the sponsor, its affiliates, or promoters; and purchasers in the
offering. See
       Item 1602(a)(5) of Regulation S-K.
2.     We note that your sponsor transferred 25,000 founder shares and 10,000
founder
       shares to each of your independent directors and to each of your
advisors. When
       discussing the amount of compensation received or to be received, as
required by Item
       1602(a)(3) of Regulation S-K, please include any compensation paid or to
be paid to
       or securities issued or to be issued to sponsor affiliates and promoters
and the price
       paid. Please also revise the tables on pages 5 and 112. See Item
1602(b)(6) of
       Regulation S-K.
 March 6, 2025
Page 2

Prospectus Summary
Our Sponsor, page 5

3.     In your compensation table here and on page 112, please revise to
include the anti-
       dilution adjustment of the founder shares. Please also revise the table
to reflect that in
       addition to your sponsor, independent directors, advisors, or their
respective affiliates
       may be paid a finder   s fee, advisory fee, consulting fee or success
fee, as referenced
       on page 38. Lastly, please revise the table to reflect that in addition
to the sponsor, an
       affiliate of the sponsor may be paid a salary or fee in connection with
the business
       combination. See Item 1602(b)(6) and Item 1603(a)(6) of Regulation S-K.
The Offering, page 18

4.     We note your disclosure on page 19 that 7,500,000 warrants will be
outstanding after
       this offering and the private placement. We further note your note (5)
on page 19
       indicates there will be 2,500,000 public warrants. Such amounts do not
appear to be
       consistent with the terms of the transaction. Please revise the number
of warrants for
       accuracy.
Ability to extend time to complete business combination, page 28

5.     Please disclose your plans if you do not consummate a de-SPAC
transaction within 24
       months, including whether there are any limitations on the number of
extensions,
       including the number of times, and the consequences to the SPAC sponsor
of not
       completing an extension of this time period. See Item 1602(b)(4) of
Regulation S-K.
Anticipated expenses and funding sources, page 28

6.     Please revise this section or include a new section within the Summary
under an
       appropriate subcaption 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 Item1602(b)(5) of
Regulation S-K.
       In this regard, we note your disclosures that you intend to target
businesses with
       enterprise values that are greater than you could acquire with the net
proceeds of this
       offering and the sale of the private placement warrants, as stated on
page 66.
Dilution, page 99

7.     Please revise your dilution disclosure on pages 99 to 101 to also
include the tabular
       dilution disclosure you have provided on the outside front cover page of
the
       prospectus. Reference is made to Item 1602(c) of Regulation S-K.
8.     We note all of the column headings are labeled as "With Over-Allotment"
in the table
       on page 100. Please revise to ensure that the column headings are
properly labeled as
       "With Over-Allotment" or "Without Over-Allotment" for each redemption
scenario in
       the table.
9.     We note inconsistent disclosure throughout in your filing with respect
to whether or
       not you cannot redeem the public shares in an amount that would cause
your net
       tangible assets to be less than $5,000,001. For example purposes only,
we noted:
 March 6, 2025
Page 3

             On page 64, you disclose that your amended and restated memorandum
and
           articles of association will not provide a specified maximum
redemption
           threshold.
           Your tabular disclosure on page 100 indicates you have assumed
$140,162,387 as
           the amount paid for redemptions in your maximum redemption scenario.
This
           tabular disclosure in inconsistent with your narrative disclosure on
page 101,
           which states that for purposes of presenting the maximum redemption
scenario,
           you have reduced your pro forma net tangible book value after this
offering
           (assuming no exercise of the underwriters    over-allotment option)
by
           $150,000,000 because holders of up to approximately 100% of your
public shares
           may redeem their shares.
           On page F-11, you state that although the Company did not specify a
           maximum redemption threshold, its charter provides that the Company
will not
           redeem its Public Shares in an amount that would cause its net
tangible assets
           (shareholder   s equity) to be less than $5,000,001.
       Please revise your filing to address these and other related
inconsistencies. Your
       revisions should clarify if you do or do not have a redemption
restriction such that you
       cannot redeem the public shares in an amount that would cause your net
tangible
       assets to be less than $5,000,001.
10.    We note that one of your calculations assumptions is that no ordinary
shares and
       convertible equity or debt securities are issued in connection with
additional financing
       in connection with an initial business combination. Please expand your
disclosure to
       highlight that you may need to do so as you intend to target an initial
business
       combination with a target company whose enterprise value is greater than
you could
       acquire with the net proceeds of the offering and the sale of private
placement
       warrants, as stated on page 66 of your prospectus.
        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.
 March 6, 2025
Page 4

       Please contact Jeffrey Lewis at 202-551-6216 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please contact Pearlyne Paulemon at 202-551-8714 or Jeffrey Gabor at
202-551-
2544 with any other questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Real Estate
& Construction
cc:   Elliott Smith