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                                                            October 21, 2024

Claudius Tsang
Chief Executive Officer and Chairman
A SPAC III Acquisition Corp.
The Sun   s Group Center
29th Floor, 200 Gloucester Road
Wan Chai
Hong Kong

       Re: A SPAC III Acquisition Corp.
           Registration Statement on Form S-1
           Filed October 1, 2024
           File No. 333-282428
Dear Claudius Tsang:

       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 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
Exhibits

1.     We note that the opinion from your BVI counsel filed as Exhibit 5.1
includes
       numerous inappropriate assumptions. Please request BVI counsel to revise
its
       opinion to remove all such inappropriate assumptions. As examples only,
we note for
       your reference the assumptions set forth in paragraphs 4 and 14. It is
not appropriate
       for a counsel to include in its opinion assumptions that assume any of
the material
       facts underlying the opinion. Refer to Section II.B.3.a of Staff Legal
Bulletin No. 19.
        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.
 October 21, 2024
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 Howard Efron at 202-551-3439 or Wilson Lee at
202-551-3468 if you
have questions regarding the financial statements and related matters. Please
contact Ronald
(Ron) E. Alper at 202-551-3329 or Dorrie Yale at 202-551-8776 with any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate & Construction
cc:   Giovanni Caruso
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