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                                                            January 10, 2025

Pankaj Khanna
Chief Executive Officer and Director
Heidmar Maritime Holdings Corp.
89 Akti Miaouli
Piraeus 18538, Greece

       Re: Heidmar Maritime Holdings Corp.
           Registrant Statement on Form F-4
           Filed December 23, 2024
           File No. 333-284004
Dear Pankaj Khanna:

       We have reviewed your 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.

Registration Statement on Form F-4
Effect of the Business Combination, page 92

1.     We note your revised disclosure at page 100 and elsewhere in the
prospectus that you
       may make any changes necessary to satisfy Nasdaq listing requirements
and to
       facilitate efficient trading. It is unclear what changes are
contemplated; whether they
       may be material changes; and whether, when, and how you intend to
communicate
       information regarding any such changes. In this regard, it is not clear
how your
       revised disclosure that you will make any changes that are necessary
satisfies your
       disclosure obligations.
 January 10, 2025
Page 2
Unaudited Pro Forma Condensed Combined Financial Information
Note 4. Adjustments to Unaudited Pro Forma Condensed Combined Financial
Information,
page 140

2.     You disclose that Heidmar expects to pay to its shareholders a dividend
immediately
       prior to the Closing equal to the amount by which its combined cash and
accounts
       receivable exceeds $10 million. Adjustment I included in the pro forma
balance sheet
       is $10 million, rather than the amount that exceeds the combined cash
and accounts
       receivable balances at June 30, 2024. Please clarify why the adjustment
is $10 million
       and revise if necessary. In addition, please remove brackets around
numbers in your
       footnote disclosures.
Exhibits

3.     We note that the Form of Consulting Agreements are to be included as
Exhibits C, D
       and E to the First Amendment to the Business Combination Agreement but
have been
       omitted. Please file with your next amendment.
General

4.     Where applicable throughout your filing, please revise to provide
updated disclosures
       for your most recently completed fiscal year. For example, please update
to disclose
       executive compensation as of the most recently completed fiscal year.

        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.

       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 Joanna Lam at 202-551-3476 or Myra Moosariparambil at
202-551-
3796 if you have questions regarding comments on the financial statements and
related
matters. Please contact Anuja Majmudar at 202-551-3844 or Daniel Morris at
202-551-3314
with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Energy &
Transportation
cc:   Keith Billotti
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