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                                                            March 3, 2025

Francis Chi Yin Ng
Co-Chief Executive Officer and Director
Copley Acquisition Corp
Suite 4005-4006, 40/F, One Exchange Square
8 Connaught Place, Central, Hong Kong

       Re: Copley Acquisition Corp
           Amendment No. 2 to Registration Statement on Form S-1
           Filed February 18, 2025
           File No. 333-283972
Dear Francis Chi Yin Ng:

     We have reviewed your amended 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. Unless
we note
otherwise, any references to prior comments are to comments in our February 12,
2025 letter.

Amendment No. 2 to Registration Statement on Form S-1 filed February 18, 2025
Proposed Business
Sponsor Information, page 123

1.     We note your response to prior comment 6 and reissue. Please revise the
tables on
       pages 16 and 126-127 to disclose the lock-up agreement between you, the
sponsor,
       and your directors and officers, on the one hand, and Clear Street, on
the other, as you
       describe on page 207 under "Lock-up."
Index to Financial Statements, page F-1

2.     Please update to include audited December 31, 2024 financial statements
pursuant to
       Regulation S-X Rule 8-08(b).
 March 3, 2025
Page 2

Exhibits

3.     Please have counsel date and sign the legal opinion filed as Exhibit
5.1. Refer to
       Section II.A.2 of Staff Legal Bulletin No. 19 and Item 601(b)(5) of
Regulation S-K.
       Please contact Frank Knapp at 202-551-3805 or Kristina Marrone at
202-551-3429 if
you have questions regarding comments on the financial statements and related
matters.
Please contact Benjamin Holt at 202-551-6614 or Pam Long at 202-551-3765 with
any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate & Construction
cc:   Michael Blankenship
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