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April 27, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Ms. Jeanne Bennett

    Mr. Brian Cascio

    Ms. Jane Park

    Ms. Loan Lauren Nguyen

    Re:

    Digital Transformation Opportunities Corp.

    Preliminary Proxy Statement on Schedule 14A

    Filed January 6, 2023

    File No. 001-40177

Ladies and Gentlemen:

On behalf of our client, Digital Transformation
Opportunities Corp. (“DTOC” or the “Company”), we are submitting this letter to notify
the Securities and Exchange Commission (the “Commission”) that the Company no longer intends to file the above-referenced
preliminary proxy statement on Schedule 14A in connection with the proposed business combination (the "Business Combination")
between the Company and American Oncology Network, LLC ("AON") - or a definitive proxy statement with respect thereto -
on a standalone basis and instead is filing a Registration Statement on Form S-4 (“Registration Statement”).
The Registration Statement includes a proxy statement/prospectus in respect of the Business Combination (the “Proxy Statement/Prospectus”)
and is being filed via EDGAR concurrently with the submission of this letter.

The Company is filing the Registration
Statement to register the issuance of shares of New AON Class A AON common stock in an exchange offer (the “Exchange
Offer”) that the Company plans to make to certain holders of units of in connection with, and prior to, the
consummation of the Business Combination. Other than the addition of disclosures pertaining to the Exchange Offer and our
responses outlined below, the content and structure of the Proxy Statement/Prospectus included in the Registration Statement remains
substantially the same as the content and structure of the above-referenced preliminary proxy statement. Accordingly, this letter is
also intended to respond to the comments of the staff of the Division of Corporate Finance (the “Staff') of the
Commission, conveyed by letter dated February 2, 2023 (the “Comment Letter”), with respect to the
above-referenced preliminary proxy statement.

For the convenience of the Staff, the numbering of the paragraphs below
corresponds to the numbering of the comment in the Comment Letter, the text of which we have incorporated into this response letter for
convenience in italicized type and which is followed by the Company's response. In the responses below, page number references are to
the Registration Statement. All references below to the text of the Proxy Statement/Prospectus and revisions and modifications related
thereto are intended to address comments by the Staff with respect to the corresponding text in the above-referenced preliminary proxy
statement. The responses and information below are based upon information provided to us by the Company and AON.

Paul Hastings LLP | 1999 Avenue of the Stars, 27th Floor, Los Angeles,
CA 90067

t: +1.310.620.5700 | www.paulhastings.com

April 27, 2023

Page 2

Summary
Term Sheet, page 2

 1. We note your disclosure on pages 4 and 14 relating to the expected ownership percentages in the combined
company of DTOC’s public stockholders, the Sponsor and other Initial Stockholders, the PIPE investors and AON equityholders. To
the extent applicable, disclose the total expected ownership of the Sponsor following the transaction, inclusive of any investments the
Sponsor plans to make through the financing transactions, such as the PIPE investment.

Response: The Company acknowledges
the Staff’s comment and respectfully advises the Staff that, at the time of this letter of response, the terms of the PIPE financing
have not yet been determined on a final and binding basis, and as such, the Company is unable to provide the expected ownership percentages
following the consummation of the proposed transaction. The Company confirms that it will update the Proxy Statement/Prospectus to provide
the requested disclosure after the determination of such terms. In the interim, the Company has modified the relevant tables on page
21 of the Registration Statement in contemplation of revised disclosure in subsequent filings following the finalization of the terms
of the PIPE financing.

Q: What are
the specific Proposals on which I am being asked to vote at the Special Meeting? page 12

 2. Revise to clarify that the proposal for the election of directors who will be the directors of the
combined company after the business combination is a proposal that can only be approved by the holders of DTOC Class B common stock, and
explain that the Sponsor and other Initial Stockholders hold such shares.

Response: The Company has revised
the Proxy Statement/Prospectus on page 19 of the Registration Statement in response to the Staff’s comment.

Questions and
Answers about the Proposals for our stockholders and the Special Meeting, page 12

 3. Please revise your disclosure in this section and elsewhere in the prospectus as appropriate to highlight
the material risks to public warrant holders, including those arising from differences between private and public warrants. Clarify whether
recent common stock trading prices exceed the threshold that would allow the company to redeem public warrants. Clearly explain the steps,
if any, the company will take to notify all shareholders, including beneficial owners, regarding when the warrants become eligible for
redemption.

Response: The Company has
revised the Proxy Statement/Prospectus on pages 8, 26-27, 91, 97, 127 and 222 of the
Registration Statement in response to the Staff’s comment.

April 27, 2023

Page 3

Q: What equity
stake will current stockholders of DTOC, PIPE Investors, and AON hold in us after the Closing?, page 14

 4. Please disclose the Sponsor and its affiliates’ total potential ownership interest in the combined
company, assuming exercise and conversion of all securities.

Response: The Company
acknowledges the Staff’s comment and respectfully advises the Staff that, at the time of this letter of response, the terms of
the PIPE financing have not yet been determined on a final and binding basis and as such, the Company is unable to provide the total
potential ownership interest in the combined company, assuming full exercise and conversion of all securities, at this time. The
Company confirms that it will update the Proxy Statement/Prospectus to provide the requested disclosure after the determination of
such terms.

 5. Revise your disclosure to show the potential impact of redemptions on the per share value of the shares
owned by non-redeeming shareholders by including a sensitivity analysis showing a range of redemption scenarios, including at least one
interim redemption level.

Response: The Company
acknowledges the Staff’s comment and respectfully advises the Staff that the Company has not included a 50% redemption
scenario due to the small range of possibilities. The Company further advises the Staff that, at the time of this letter of
response, the terms of the PIPE financing have not yet been determined on a final  and binding basis and that, as a result, no
disclosure regarding the potential impact of various redemption scenarios can be made at this time. The Company confirms that it
will update the Proxy Statement/Prospectus to provide the requested disclosure after determination of such terms.

 6. Please revise to disclose all possible sources and extent of dilution that shareholders who elect not
to redeem their shares may experience in connection with the business combination. Provide disclosure of the impact of each significant
source of dilution, including the amount of equity held by founders, convertible securities, including warrants retained by redeeming
shareholders, at each of the redemption levels detailed in your sensitivity analysis, including any needed assumptions.

Response: The Company
acknowledges the Staff’s comment and respectfully advises the Staff that, at the time of this letter of response, the terms of
the PIPE financing have not yet been determined on a final and binding basis, and as such, the Company is unable to provide
disclosure of the sources and extent of dilution for non-redeeming shareholder. The Company confirms that it will update the Proxy
Statement/Prospectus to provide the requested disclosure after determination of such terms. In the interim, the Company has modified
the relevant tables in the Proxy Statement/Prospectus to include certain assumptions in contemplation of the Company’s revised
disclosure in subsequent filings following the finalization of the terms of the PIPE financing.

April 27, 2023

Page 4

Q: If I am a
holder of warrants, can I exercise redemption rights with respect to my warrants?, page 18

 7. Quantify the value of warrants, based on recent trading prices, that may be retained by redeeming stockholders
assuming maximum redemptions and identify any material resulting risks.

Response: The Company has revised
the Proxy Statement/Prospectus on pages 26 and 27 of the Registration Statement in response to the Staff’s comment.

Summary of the
Proxy Statement, page 25

 8. Please revise to expand your descriptions of DTOC and AON in this section. Please expand your disclosure
to discuss the types of products and services AON provides and how it generates revenue. Please also balance your disclosure to include
equally prominent disclosure of the limitations and challenges you face in implementing your business strategy, including but not limited
to, your net income (loss) for the year ended December 31, 2021 and your dependence on a limited number of payors. Please also disclose
that the audit opinion for DTOC includes a paragraph related to substantial doubt about the ability of DTOC to continue as a going concern.

Response: The Company has revised
the Proxy Statement/Prospectus on page 38 of the Registration Statement in response to the Staff’s comment.

 9. We refer to your organizational structure chart of New AON following the consummation of the business
combination on page 32. Please revise include the variable interest entities, American Oncology Partners, P.A. and American Partners of
Maryland, P.A., as well as American Oncology Management Company, LLC, the primary beneficiary, as identified on page 158. Please also
revise to indicate the entity that owns the equity in each depicted entity. In the revised presentation, please highlight that these entities
are variable interest entities.

Response: The Company has
revised the organizational chart of New AON following the consummation of the business combination on pages 45 and 182 of the
Registration Statement in response to the Staff’s comment.

Interests of
DTOC Directors and Officers and Others in the Business Combination, page 43

 10. Please revise your disclosure to include the current value of out-of-pocket expenses for which the
Sponsor and DTOC’s officers and directors and their affiliates are awaiting reimbursement.

Response: The Company has revised
the Proxy Statement/Prospectus on page 221 of the Registration Statement to include the current value of out-of-pocket expenses.

April 27, 2023

Page 5

 11. We note your disclosure that the Sponsor and each of the members of the DTOC Board and executive management
team have agreed to waive their redemption rights in connection with the consummation of the Business Combination with respect to any
shares of DTOC common stock held by them. Please describe here and elsewhere in the prospectus any consideration provided in exchange
for this agreement. Please also revise your disclosure summarizing the background of the business combination to discuss the negotiation
of this agreement.

Response: The Company has revised
the Proxy Statement/Prospectus on  page 138 of the Registration Statement in response to the Staff’s comment. As described
in the Letter Agreement dated March 9, 2021, a copy of which was filed as Exhibit 10.4 to the Current Report on Form 8-K filed by the
Company on March 12, 2021, our sponsor, directors and officers agreed to waive their redemption rights with respect to any shares of
our common stock that they may hold in connection with the consummation of a business combination “to induce the Company and the
Underwriter to enter into the Underwriting Agreement and to proceed with the Public Offering.” No additional consideration was
provided in exchange for the Letter Agreement. Accordingly, as the Letter Agreement was executed prior to any negotiations between the
Company and AON, we have not included disclosure in the “Background of the Business Combination” section.

 12. It appears that underwriting fees remain constant and are not adjusted based on redemptions. Revise
your disclosure to disclose the effective underwriting fee on a percentage basis for shares at each redemption level presented in your
sensitivity analysis related to dilution.

Response: The Company acknowledges
the Staff’s comment and has revised the Proxy Statement/Prospectus on page 22 of the Registration Statement in response to the
Staff’s comment. The Company respectfully advises the Staff that, at the time of this letter of response, the terms of the PIPE
financing have not yet been determined on a final and binding basis and that, as a result, no disclosure regarding the effective underwriting
fee can be made at this time. The Company confirms that it will update the Proxy Statement/Prospectus to provide the requested disclosure
after determination of such terms.

 13. We note your disclosure on page 121 that DTOC’s current charter waives the corporate opportunities
doctrine. Please address this potential conflict of interest and whether it impacted your search for an acquisition target here and elsewhere
in the proxy statement.

Response: The Company has
revised the Proxy Statement/Prospectus on pages 8, 127, 139 and 222 of the Registration Statement in response to the Staff’s
comment.

April 27, 2023

Page 6

DTOC’s Sponsor and certain of its directors
and officers have potential conflicts of interest..., page 76

 14. Please revise to highlight the risk that the Sponsor will benefit from the completion of a business
combination and may be incentivized to complete an acquisition of a less favorable target company or on terms less favorable to shareholders
rather than liquidate. Please also clarify if the Sponsor and its affiliates can earn a positive rate of return on their investment, even
if other SPAC shareholders experience a negative rate of return in the post-business combination company.

Response: The Company has revised
the Proxy Statement/Prospectus on pages 8, 90, 91, 92, 127 and 222 of the Registration Statement in response to the Staff’s comment.

Risks Related
to DTOC and the Business Combination, page 76

 15. Disclose the material risks to unaffiliated investors presented by taking the company public through
a merger rather than an underwritten offering. These risks could include the absence of due diligence conducted by an underwriter that
would be subject to liability for any material misstatements or omissions in a registration statement.

Response: The Company has revised
the Proxy Statement/Prospectus on page 93 of the Registration Statement in response to the Staff’s comment.

We may be
required to call another special meeting of its stockholders to request an amendment..., page 84

 16. Please update your disclosure here to clarify that the Sponsor has elected to exercise, in its sole
discretion, the extension option to extend the combination period to complete an initial business combination to June 30, 2023 and describe
the loan from the Sponsor relating to the additional extension period.

Response: The Company has revised
the Proxy Statement/Prospectus on  pages 3, 4, 142, 144 and 196 of the Registration Statement in response to the Staff’s comment.

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