May 12, 2025

Scott LaPorta
Chief Executive Officer
Vendome Acquisition Corp I
1090 Center Drive
Park City, UT 84098

       Re: Vendome Acquisition Corp I
           Registration Statement on Form S-1
           Filed April 15, 2025
           File No. 333-286534
Dear Scott LaPorta:

       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 April 15, 2025
Our Sponsor, page 3

1.     In the table of compensation and securities issued or to be issued,
please include the
       105,000 founder shares your sponsor will transfer to your independent
director
       nominees and certain members of your management team for their services,
in each
       case for no cash consideration, including 25,000 shares to each of your
independent
       directors and 30,000 shares to Amy Wang. Please also include this
disclosure on the
       cover page and disclose the anti-dilution adjustment of the founder
shares in the table
       in the Summary, as required by Items 1602(a)(3) and 1602(b)(6) of
Regulation S-K.
2.     We note that the managing member of your sponsor is Vendome Acquisition
Holding
       I LLC, of which your founders are the sole members and your founders
control the
       management of the sponsor, including the exercise of voting and
investment
       discretion over the securities of your company held by your sponsor.
Please revise to
       disclose all persons or affiliated groups who have direct or indirect
material interests
 May 12, 2025
Page 2

       in the sponsor, as well as the nature and amount of their interests. See
Item 1603(a)(7)
       of Regulation S-K.
Risk Factors, page 46

3.     With a view toward disclosure, please tell us whether your sponsor is,
is controlled
       by, has any members who are, or has substantial ties with, a non-U.S.
person. Also
       revise your filing to include risk factor disclosure that addresses how
this fact could
       impact your ability to complete your initial business combination. For
instance,
       discuss the risk to investors that you may not be able to complete an
initial business
       combination with a target company should the transaction be subject to
review by a
       U.S. government entity, such as the Committee on Foreign Investment in
the United
       States (CFIUS), or ultimately prohibited. Disclose that as a result, the
pool of potential
       targets with which you could complete an initial business combination
may be
       limited. Further, disclose that the time necessary for government review
of the
       transaction or a decision to prohibit the transaction could prevent you
from
       completing an initial business combination and require you to liquidate.
Disclose the
       consequences of liquidation to investors, such as the losses of the
investment
       opportunity in a target company, any price appreciation in the combined
company,
       and the warrants, which would expire worthless.
Dilution, page 95

4.     We note that the tables on pages 95     96 do not reflect a redemption
restriction with
       respect to your public shares. However, disclosure throughout your
filing states that
       your amended and restated memorandum and articles of association
provides that
       under no circumstances will you redeem your public shares in an amount
that would
       cause your net tangible assets, after payment of the deferred
underwriting
       commissions to be less than $5,000,001. Please reconcile your
disclosures for us or
       revise accordingly. Please refer to Item 1602 of Regulation S-X.
5.     Please expand your narrative disclosure to describe each material
potential source of
       future dilution. Your revisions should address, but not be limited to,
shares that may
       be issued in connection with the exercise of the public warrants and the
private
       placement warrants. Reference is made to Item 1602(c) of Regulation S-K.
6.     We note that your calculations assume that you will not issue any
ordinary shares as
       part of the combination consideration, and 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 your disclosure on page 3
indicates you intend
       to target businesses with enterprise values of $500 million, which is
greater than you
       could acquire with the net proceeds of this offering and the sale of the
private
       placement warrant as stated on page 100 of your prospectus.
Principal Shareholders, page 150

7.     Please revise the table to include the shares to be transferred to
independent directors
       and members of your management team as described on page 153, or advise.
 May 12, 2025
Page 3
Note 2 - Summary of Significant Accounting Policies
Recent Issued Accounting Pronouncements, page F-12

8.     Please tell us how you determined that your disclosure is compliant with
the segment
       disclosures for single reportable segment entities under ASC
280-10-50-20 and ASU
       2023-07, or revise your footnotes to include the applicable disclosures.

        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.

        Please contact William Demarest at 202-551-3432 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 Mary Beth Breslin
at 202-
551-3625 with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate & Construction
cc:   Gil Savir