March 24, 2025

Julian Sevillano
Chief Executive Officer
WEN Acquisition Corp
180 Grand Avenue
Suite 1530
Oakland, CA 94612

        Re: WEN Acquisition Corp
            Draft Registration Statement on Form S-1
            Submitted February 25, 2025
            CIK No. 0002057043
Dear Julian Sevillano:

       We have reviewed your 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.

Draft Registration Statement on Form S-1
Cover Page

1.     Please describe on the cover page and in the summary the anti-dilution
adjustments
       that may result in the issuance of additional securities to the sponsor,
its affiliates and
       promoters in connection with any change in the size of the offering to
maintain the
       number of founder shares at 20% upon the offering   s consummation. We
note your
       disclosure on page 19 that you may increase or decrease the size of the
offering
       pursuant to Rule 462(b) under the Securities Act. Please disclose on the
cover page
       whether and the extent to which these securities issuances may result in
a material
       dilution of the purchaser   s equity interests, as required by Items
1602(a)(3) of
       Regulation S-K.
 March 24, 2025
Page 2

Proceeds to be held in trust account, page 22

2.     Please reconcile the disclosure in this section that funds held in the
trust account may
       be released to pay taxes with the disclosure on page 51 that funds may
be released to
       pay certain other expenses and on page 89 which references the release
of funds up to
       $100,000 to pay dissolution expenses.
Conflicts of Interest, page 33

3.     We note your disclosure that your sponsor, officers and directors could
have conflicts
       of interest in determining whether to present business combination
opportunities to
       you or to any other SPAC with which they may become involved. Please
revise your
       conflicts disclosure to reflect the current involvement of certain
members of your
       management with existing SPACs such as Launch One Acquisition Corp and
Launch
       Two Acquisition Corp and clarify how opportunities to acquire targets
are allocated
       among SPACs. See Items 1602(b)(7) and 1603(b) of Regulation S-K.
Dilution, page 92

4.     We refer to your tables beginning on page 92 showing your calculations
of net
       tangible book value presented in quartile intervals assuming full
exercise and no
       exercise of the over-allotment option. It appears the calculations
labeled    With Over-
       Allotment    are made assuming no exercise of the over-allotment option
and the
       calculations labeled    Without Over-Allotment    are made assuming full
exercise of the
       over-allotment option. Please reconcile and revise your presentation
throughout your
       filing to properly label the assumptions used in your calculations.
5.     Please expand your disclosure outside the table to highlight that you
may need to issue
       additional securities as you intend to seek an initial business
combination with a target
       company with an enterprise value greater than the net proceeds of the
offering and the
       sale of private placement warrants, as stated on page 10 of your
prospectus.
SPAC Experience, page 101

6.     For each of the SPAC business combinations referenced in this section
please revise
       to disclose the financing needed for the transactions. Also, disclose
the level of
       redemptions for FTAC Olympus Acquisition Corp.
Restrictions on Transfers of Founder Shares and Private Placement Warrants,
page 147

7.     Please reconcile your disclosure in this section regarding the transfer
of securities by
       Cantor Fitzgerald with the disclosure on pages 13 and 112.
 March 24, 2025
Page 3

       Please contact Jeffrey Lewis at 202-551-6216 or Isaac Esquivel at
202-551-3395 if
you have questions regarding comments on the financial statements and related
matters. Please contact Ruairi Regan at 202-551-3269 or Mary Beth Breslin at
202-551-3625
with any other questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Real Estate
& Construction
cc:   Stuart Neuhauser, Esq.