United States securities and exchange commission logo September 14, 2021 Shahal Khan Chief Executive Officer BurTech Acquisition Corp. 1300 Pennsylvania Ave NW, Suite 700 Washington, DC 20004 Re: BurTech Acquisition Corp. Registration Statement on Form S-1 Filed on August 19, 2021 File No. 333-258914 Dear Mr. Khan: We have limited our review of your registration statement to those issues we have addressed in our comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. 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 comment, we may have additional comments. Form S-1 filed August 19, 2021 Capitalization, page 79 1. We note that you are offering 25,000,000 Class A common shares as part of your initial public offering of units, but only show 23,742,449 Class A common shares subject to possible redemption in your Capitalization table. Please tell us how you considered the guidance in ASC 480-10-S99-3A, which requires securities that are redeemable for cash or other assets to be classified outside of permanent equity if they are redeemable (1) at a fixed or determinable price on a fixed or determinable date, (2) at the option of the holder, or (3) upon the occurrence of an event that is not solely within the control of the issuer, in concluding that all 25,000,000 Class A common shares were not required to be presented outside of permanent equity and part of shares subject to possible redemption. Shahal Khan BurTech Acquisition Corp. September 14, 2021 Page 2 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. You may contact Howard Efron at 202-551-3439 or Shannon Menjivar at 202-551-3856 if you have questions regarding comments on the financial statements and related matters. Please contact Melanie Singh at 202-551-4074 or Brigitte Lippmann at 202-551-3713 with any other questions. Sincerely, FirstName LastNameShahal Khan Division of Corporation Finance Comapany NameBurTech Acquisition Corp. Office of Real Estate & Construction September 14, 2021 Page 2 cc: G. Alex Weniger-Araujo FirstName LastName