United States securities and exchange commission logo





                              March 4, 2022

       Jiang Hui
       Chief Executive Officer
       Hudson Acquisition I Corp.
       19 West 44th Street, Suite 1001
       New York, NY 10036

                                                        Re: Hudson Acquisition
I Corp.
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted February
10, 2022
                                                            CIK No. 0001853047

       Dear Mr. Hui:

             We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 1 to Draft Registration Statement on Form S-1

       General

   1.                                                   We note that you have
added a PRC geographic target carve-out related to your initial
                                                        business combination.
Please provide the language of the provision which will be
                                                        contained in your
Second Amended and Restated Certificate of Incorporation.
       Anticipated Expenses and Funding Sources, page 13

   2.                                                   We note your response
to our prior comment 1 and reissue in part. We note your
                                                        disclosure that you
"currently intend to draw approximately $210,000 upon the
                                                        Promissory Note to fund
[your] operations for the initial ten (10) months after the
 Jiang Hui
Hudson Acquisition I Corp.
March 4, 2022
Page 2
         completion of this offering." We also note your disclose on page 55
that you have already
         drawn $300,000 as of September 30, 2021. Please reconcile or advise.
Limited Payments to Insiders, page 22

3.       Please revise the third bullet to quantify the current amount
outstanding under the
         Promissory Note.
4.       We note your disclosure on page 13 that the time to complete an
initial business
         combination may be extended via certain payments by your sponsor or
its affiliates or
         designees. We also note your disclosure that such payments would be
made in the form of
         non-interest bearing loans. Please revise this section, and the
prospectus throughout
         accordingly, to discuss these loans and address any repayment terms or
conditions
         including if the company fails to complete an initial business
combination.
       You may contact Tony Watson at 202-551-3318 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Janice Adeloye at 202-551-3034 or Donald Field at 202-551-3680 with any
other
questions.



FirstName LastNameJiang Hui                                    Sincerely,
Comapany NameHudson Acquisition I Corp.
                                                               Division of
Corporation Finance
March 4, 2022 Page 2                                           Office of Trade
& Services
FirstName LastName