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                                                             April 7, 2025

Stephen Herbert
Chief Executive Officer
Armada Acquisition Corp. II
1760 Market Street, Suite 602
Philadelphia, PA 19103

       Re: Armada Acquisition Corp. II
           Registration Statement on Form S-1
           Filed March 26, 2025
           File No. 333-286110
Dear Stephen Herbert:

       We have reviewed your registration statement and have the following
comment.

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe our 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
Certain Relationships and Related Party Transactions, page 148

1.     We note your revised disclosure that the non-managing investors have
committed,
       pursuant to written agreements, to purchase, indirectly through the
purchase of non-
       managing membership interests in the Sponsor, an aggregate of 300,000
private
       placement units out of the 400,000 private placement units to be
purchased by the
       Sponsor. Please disclose the persons who may have direct and indirect
material
       interests in the sponsor, as well as the nature and amount of their
interests. See Item
       1603(a)(7) of Regulation S-K.
        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.
 April 7, 2025
Page 2

       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 Ruairi Regan at 202-551-3269 or David Link at
202-551-3356 with
any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate & Construction
cc:   Gerry Williams, Esq.
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