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    Bank of America Tower

    800 Capitol Street, Suite 2200

    Houston, TX 77002

    (713) 354-4900

December 14, 2022

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Mark Rakip and Kristi Marrone, Division of Corporation Finance, Office of Real Estate & Construction

    Re:
    LatAmGrowth SPAC

    Form 10-K for fiscal year ended December 31, 2021

    Filed April 13, 2022

    File No. 001-41216

Dear Ladies and Gentlemen:

On behalf of our client, LatAmGrowth SPAC (the “Company”),
we submit this letter setting forth the responses of the Company to the comments provided by the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) in its comment letter dated December 8, 2022 (the
“Comment Letter”) with respect to Company’s annual report for the year ended December 31, 2021, on Form
10-K filed with the Commission by the Company on April 13, 2022 (the “Annual Report”).

For your convenience, we have reproduced below in italics the text
of the Comment Letter, followed by the Company’s response. Capitalized terms used but not defined herein shall have the meanings
assigned to such terms in the Annual Report.

Form 10-K for the Fiscal Year Ending December 31, 2021

Cover Page

    1.
    With a view toward disclosure, please tell us whether your sponsor is, is controlled by, or has substantial ties with a non-U.S. person. If so, please revise your disclosure in future filings to include disclosure that addresses how this fact could impact your ability to complete your initial business combination. For instance, discuss the risk to investors that you may not be able to complete an initial business combination with a U.S. target company should the transaction be subject to review by a U.S. government entity, such as the Committee on Foreign Investment in the United States (CFIUS), or ultimately prohibited. Disclose that as a result, the pool of potential targets with which you could complete an initial business combination may be limited. Further, disclose that the time necessary for government review of the transaction or a decision to prohibit the transaction could prevent you from completing an initial business combination and require you to liquidate. Disclose the consequences of liquidation to investors, such as the losses of the investment opportunity in a target company, any price appreciation in the combined company, and the warrants, which would expire worthless. Please include an example of your intended disclosure in your response.

    Securities and Exchange Commission

Division of Corporation Finance

    December 14, 2022

Page 2

Company Response

The Company acknowledges the Staff’s
comment and in future filings we will disclose how this fact could impact our ability to complete an initial business combination. The
Company respectfully informs the Staff that its sponsor, LatAmGrowth Sponsor LLC, a Delaware limited liability company, is controlled
by, or has substantial ties with, non-U.S. persons domiciled in Mexico.

In the interest of disclosure, the Company
intends to include in its future Forms 10-Q and Forms 10-K filed with the Commission prior to the completion of its initial business combination,
and if appropriate, any definitive proxy and/or registration statement to be filed with the Commission in connection with its initial
business combination, the following language highlighting the risks to investors that we may not be able to complete an initial business
combination with a U.S. target company should the transaction be subject to review by a U.S. government entity, such as the Committee
on Foreign Investment in the United States (CFIUS).

“If we were considered to
be a “foreign person,” we might not be able to complete an initial business combination with a U.S. target company if such
initial business combination is subject to U.S. foreign investment regulations or review by a U.S. government entity, such as the Committee
on Foreign Investment in the United States (“CFIUS”).

Our Sponsor is controlled by, or has
substantial ties with non-U.S. persons domiciled in Mexico. Acquisitions and investments by non-U.S. Persons in certain U.S. business
may be subject to rules or regulations that limit foreign ownership. CFIUS is an interagency committee authorized to review certain transactions
involving investments by foreign persons in U.S. businesses that have a nexus to critical technologies, critical infrastructure and/or
sensitive personal data in order to determine the effect of such transactions on the national security of the United States. Were we considered
to be a “foreign person” under such rules and regulations, any proposed business combination between us and a U.S. business
engaged in a regulated industry or which may affect national security could be subject to such foreign ownership restrictions, CFIUS review
and/or mandatory filings.

If our potential initial business combination
with a U.S. business falls within the scope of foreign ownership restrictions, we may be unable to consummate an initial business combination
with such business. In addition, if our potential business combination falls within CFIUS’s jurisdiction, we may be required to
make a mandatory filing or determine to submit a voluntary notice to CFIUS, or to proceed with the initial business combination without
notifying CFIUS and risk CFIUS intervention, before or after closing the initial business combination. CFIUS may decide to block or delay
our initial business combination, impose conditions to mitigate national security concerns with respect to such initial business combination
or order us to divest all or a portion of a U.S. business of the combined company if we had proceeded without first obtaining CFIUS clearance.
The potential limitations and risks may limit the attractiveness of a transaction with us or prevent us from pursuing certain initial
business combination opportunities that we believe would otherwise be beneficial to us and our shareholders. As a result, the pool of
potential targets with which we could complete an initial business combination may be limited and we may be adversely affected in terms
of competing with other special purpose acquisition companies which do not have similar foreign ownership issues. Moreover, the process
of government review, whether by CFIUS or otherwise, could be lengthy.

Because we have only a limited time
to complete our initial business combination, our failure to obtain any required approvals within the requisite time-period may require
us to liquidate. If we liquidate, our public stockholders may only receive their pro rata share of amounts held in the trust account,
and our warrants will expire worthless. This will also cause you to lose any potential investment opportunity in a target company and
the chance of realizing future gains on your investment through any price appreciation in the combined company.”

    SHEARMAN.COM

    Shearman & Sterling LLP is a limited liability partnership organized in the United States under the laws of the state of Delaware, which laws limit the personal liability of partners.

    Securities and Exchange Commission

Division of Corporation Finance

    December 14, 2022

Page 3

We hope that the foregoing has been responsive
to the Staff’s comments. Please direct any questions or comments regarding the foregoing to William B. Nelson at +1.713.354.4880
and Emily Leitch at +1.713.377.8333.

Very truly yours,

  /s/ William B. Nelson

    cc:
    Gerard Cremoux

    LatAmGrowth SPAC

    SHEARMAN.COM

    Shearman & Sterling LLP is a limited liability partnership organized in the United States under the laws of the state of Delaware, which laws limit the personal liability of partners.