Giovanni Caruso
	Partner
	345 Park Avenue	Direct	212.407.4866
	New York, NY 10154	Main	212.407.4000
		Fax	212.937.3943
		[email protected]

May 23, 2025

Ameen Hamady
Kristina Marrone
Isabel Rivera
Benjamin Holt

Division of Corporation Finance

U.S. Securities & Exchange Commission

Office of Real Estate & Construction

100 F Street, NE

Washington, D.C. 20549

Ladies and Gentlemen:

On behalf of our client, BEST SPAC I Acquisition Corp. (the “Company”), we hereby provide a response to the comments issued in a letter dated April 10, 2025 (the “Staff’s Letter”) regarding the above-referenced Registration Statement on Form S-1 (the “Registration Statement”). Contemporaneously, the Company is filing a revised Registration Statement via EDGAR (the “Amended Registration Statement”), which reflects the Company’s responses to the comments received by the Staff and certain updated information.

In order to facilitate the review by the staff of the Securities and Exchange Commission (the “Staff”) of the Amended Registration Statement, we have responded, on behalf of the Company, to the comment set forth in the Staff’s Letter. The numbered paragraphs set forth below respond to the Staff’s comments and correspond to the numbered paragraph in the Staff’s Letter.

Registration Statement on Form S-1 filed March 28, 2025

Note 2 - Basis of Presentation and Summary of Significant Accounting Policies Recent Accounting Pronouncements, page F-12

Response: In response to the Staff’s comment, the Company has revised the disclosure on pages F-33-34 of the Amended Registration Statement.

U.S. Securities and Exchange Commission May 23, 2025 Page 2

Please call me at (212) 407-4866 if you would like additional information with respect to any of the foregoing. Thank you.