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CORRESP
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Western Acquisition Ventures Corp.

42 Broadway, 12th Floor

New York, NY 10004

November 1,
2024

Via EDGAR

Morgan Youngwood, Senior Staff Accountant

Stephen Krikorian, Accounting Branch Chief

Jeff Kauten, Staff Attorney

Jan Woo, Staff Attorney

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, DC 20549

    Re:
    Western Acquisition Ventures
    Corp.

    Amendment No. 4 to Registration Statement
    on Form S-4

    Filed August 12, 2024

    File No. 333-269724

Ladies and Gentlemen:

Western Acquisition Ventures Corp. (the “Company”)
is writing to respond to the comments set forth in the letter of the staff of the U.S. Securities and Exchange Commission (the “Staff
 ”) dated August 26, 2024 (the “Staff Letter”), related to the above-referenced Amendment No. 4
(“Amendment No. 4”), which was filed on August 12, 2024, to the Company’s Registration Statement
on Form S-4 (the “Form S-4”), which was filed on February 13, 2023. In response to the comments
in the Staff Letter, the Company has further revised the Form S-4, and the Company filed via EDGAR a fifth amendment to the Form S-4
(“Amendment No. 5”) and now provides this response letter.

The Company has reproduced below in bold italics
the Staffs comments in the order in which they were set out in the Staff Letter, numbered correspondingly, and has provided the Company’s
response immediately below each comment.

Amendment No. 4 to Registration Statement
on Form S-4

Unaudited Pro Forma Condensed Combined Financial
Information Description and Accounting for the Potential Acquisition of SLG, page 44

    1.
    Please revise to disclose your basis for consolidating SLG as described in your response to prior comment 1. Please provide a detailed analysis of how you concluded that you are the primary beneficiary of SLG and explain whether the consolidation will result in a non- controlling interest in SLG.

Response:

The Company respectfully advises the Staff that the management of Cycurion has performed an analysis of the relationship between Cycurion
and SLG. The following are the primary facts and circumstances that Cycurion has considered in its analysis: post merger, Cycurion will
own 49% equity interest on SLG, Ed Burns will own the remaining 51% of SLG, but he has pledged all of his voting power and economic benefits
derived from ownership to Cycurion. Cycurion will direct Ed Burns to vote as shareholder to elect board members of SLG; Ed will be holding
the shares in trust on behalf of Cycurion so that SLG continues to qualify to bid for government contracts in the Illinois area as a domestic
entity. These facts indicate that Cycurion is the primary beneficiary of the relationship.

Additional facts to consider: (i) operationally,
other than services subcontracted to RCR, Cycurion is the primary subcontractor on all SLG contract with customers; Cycurion renders a
large proportion services to SLG's customers, (ii) Cycurion will take over all accounting and finance functions from SLG upon completion
of the merger, (iii) Cycurion has been and will continue to provide financing to SLG; SLG was previously under capitalized and needed
Cycurion to provide financial resources to allow for SLG to maintain operations. These facts lead to the conclusion that in SLG is a variable
interest entity of Cycurion, and a true and fair presentation would require Cycurion to consolidate the accounts of SLG as wholly owned
subsidiary, where all benefits and obligations belong to Cycurion.

Basis of Pro Forma Presentation, page 46

    2.
    We note from your response to prior comment 2 that you provided reconciliations or cross references for some of the Cycurion [Pre-Merger] and Cycurion [Post-Merger] amounts. Please reconcile or cross reference each of the Cycurion [Pre-Merger] amounts presented in your table on the cover page to your consolidated financial statements. Reconcile each of the Cycurion [Post-Merger] amounts in your table on the cover page to your table on page 47 that shows possible sources of dilution and illustrates estimated ownership of common stock in the Combined Company immediately following the consummation of the Business Combination. In this respect, reconcile the Cycurion [Post-Merger] amounts on the cover page to the 12,000,000 estimated ownership of common stock in the Combined Company by the "The Sellers" and the 24,413,208 shares attributable to the Series B and D Preferred stock and related warrants.

Response:

The Company respectfully advises the
Staff that it has updated the disclosure on page 57 of Amendment No. 5 to the Cycurion [Pre-Merger] and Cycurion [Post-Merger]
amounts.

    3.
    We note from your table on page 47 that there are 24,413,208 Series B and D Preferred stock and related warrants. Please reconcile
this amount with your footnote that indicates this amount includes 6,000,000 shares of common stock underlying the Series B preferred
stock (including 710,000 shares converted from 355 shares of Series B preferred stock at closing of the Business Combination), 6,666,667
shares of common stock underlying the Series D Preferred stock, 472,813 shares of common stock issued with the Series D Preferred
stock, and 13,272,728 shares of common stock underlying warrants.

Response:

The Company respectfully advises
the Staff that there are 26,412,208 Series B and D Preferred stock and related warrants and has updated the table on
page 48 of Amendment No. 5. For more information, please also see the tables found on pages 18 and 86 and the
disclosure found on page 55 of Amendment No. 5 and the table below.

    Preferred
    Warrant
    Stock to be Issued
    Total

    Series B Preferred (*)
      6,000,000
      6,000,000

    12,000,000

    Series D Preferred
      6,666,667

    6,666,667

    Warrant A

      6,666,667

    6,666,667

    Warrant B

      606,061

    606,061

    Common Shares

      472,813
    472,813

      12,666,667
      13,272,728
      472,813
    26,412,208

Note 3 - Adjustments to Unaudited Pro Forma Condensed Combined Financial
Information, page 54

    4.
    We note your response to prior comment 7. Please explain how you calculated $14,139,026 of goodwill in connection with the business combination of SLG. Explain your consideration of including the "Elimination of receivables in Cycurion owing from SLG" in the estimated purchase consideration. Explain whether your calculation of goodwill excludes the payable to RCR. In this respect, we note from your response that the RCR transaction is being settled separately from the other preexisting business relationships.

Response:

The Company respectfully advises the
Staff that goodwill has been updated in the document starting on page 57 of Amendment No. 5. Goodwill is calculated as follows,
which more clearly shows how inter-company balances and payables to RCR are eliminated, which does not impact the calculation of goodwill,
as these are offset by assets recorded in Western and Cycurion. The payables to RCR is settled by issuing Western shares, meaning that
Western records due from SLG and SLG records due to Western, create new inter-company balances.

 · Consideration – $7,545,472.

 · Net assets – ($6,056,942) after eliminating inter-company balances.

 · Goodwill – $14,047,434.

    Consideration
    $ 7,545,472

    Asset acquired

    Cash
      16,168

    Accounts receivable, net
      3,780,429

      3,796,597

    Labilities assumed

    Accounts payable and accrued liabilities, net of $2.1 million payable to Cycurion and $2.1 million payable to RCR
      (2,138,912 )

    Factoring liability
      (2,581,163 )

    Loans payable and advances
      (1,336,867 )

      (6,056,942 )

    Net assets
      (2,260,345 )

    Elimination of inter-company balances

    Elimination of receivables in Cycurion owing from SLG
      2,132,172

    Elimination of due from SLG (settlement of payable to RCR)
      2,136,445

      4,268,617

    Total net assets
      (6,528,962 )

    Goodwill
    $ 14,074,434

 (1) Reconciliation of assumed accounts payable and accrued liabilities, net:

    SLG accounts payable and accrued liabilities
    $ 6,407,529

    Less the amount owing to RCR settled by WAVS' common stock
      (2,136,445 )

    Less amount owing to Cycurion
      (2,132,172 )

    Net liabilities of SLG
    $ 2,138,912

 (2) Elimination of inter-company balances:

 · Cycurion has a receivable owing from SLG, this is also eliminated on acquisition and is matching the payable
eliminated for SLG.

 · On settlement of the amount owing to RCR, this settlement was paid by the common stock of WAVS. SLG now
owes WAVS $2,136,445. This is being eliminated on the acquisition of SLG.

Proposal 1 - The Business Combination Proposal
Background of the Business Combination, page 87

    5.
    Please disclose when and the reasons why the Merger Consideration Shares were increased from 9.5 million shares to 12 million shares.

Response:

The Company respectfully advises
the Staff that it has updated its disclosure on pages 97-98 to disclose when and the reasons why the Merger Consideration Shares
were increased from 9.5 million shares to 12 million shares.

From
January 2024 to April 2024, the Company and Cycurion negotiated and exchanged drafts of the Business Combination Agreement,
which, among other things, would amend the Business Combination Agreement to remove Section 9.1(d), which limits redemptions
by public stockholders if such redemptions would result in the Company having net tangible assets that are less than $5,000,001. The purpose
of the net asset test limitation was initially to ensure that the Company’s common stock would not be deemed to be a “penny
stock” pursuant to Rule 3a51-1 under the Securities Exchange Act of 1934 (the “Exchange Act”). Since
the Company’s common stock and the Combined Company’s Common Stock would not be deemed to be a “penny stock,”
because the Company otherwise is exempt from the provisions of Rule 419 promulgated under the Exchange Act, as such securities are
or will be listed on a national securities exchange upon the closing, the Company presented the NTA Proposal in Amendment No. 4 to
facilitate the consummation of the Business Combination. Both the Company and Cycurion reasonably believe, given the SLG Acquisition
(as defined below), that the net tangible assets of Cycurion would qualify the Combined Company to be listed on a national securities
exchange upon the closing of the Business Combination.

When
the Company and Cycurion entered into the original Business Combination Agreement, the parties determined that the issuance or reservation
for issuance of an aggregate of 9.5 million shares of Company capital stock (allocated among the then-issued and outstanding shares of
capital stock of Cycurion, and diluted for conversions of Cycurion’s then-outstanding convertible obligations and exercises of Cycurion’s
then-outstanding warrants) was fair for the respective stakeholders on each side of the proposed transaction. During the months thereafter,
and due to the continuing series of delays in the consummation of the Business Combination, which exacerbated the continuing financial
requirements for both parties, Cycurion (directly) and the Company (indirectly) engaged in certain dilutive financing transactions. Further,
due to the continuing pre-consummation, and expected post-consummation, financial needs of the parties, and the current lack of funds
in the Company’s treasury (as distinct from the parties’ earlier beliefs) all coalesced into further discussions between the
parties to modify the prospective aggregate issuances by the Company of shares of its capital stock.

Further, on January 10,
2024, with reference to the SLG Term Sheet that had been amended on April 29, 2024 to extend the expiration of the term sheet and
the transactions contemplated thereby to the soonest of: (i) closing of the transactions contemplated thereby, (ii) April 30,
2024, if the transactions contemplated thereby have not closed by then, (iii) Cycurion’s termination thereof, and (iv) the
mutual termination by all of the parties thereto, Cycurion and SLG discussed an extension of the outside date of Cycurion’s acquisition
of SLG (the “SLG Acquisition”) to September 30, 2024.

During the period between
July 2024, and September 2024, representatives of the Company and Cycurion updated their expectations that the SLG Acquisition
will close and their updated reasonable belief that the closing is expected to occur shortly after the consummation of the Business Combination.

After
the series of financings and the SLG Acquisition discussions, in early August 2024, the Company and Cycurion formally agreed to increase
the originally agreed Merger Consideration of 9.5 million shares to the updated 12 million shares to offset the increased dilution to
the legacy Cycurion equity holders as result of the financings and the determination to close the SLG Acquisition.

By
way of further explanation of the dilutive effect of the Series B and Series D preferred stock and warrant financings (the “Relevant
Financings”):

 · Pre-Relevant Financings and with 9.5 million shares to be issued
at the closing, the legacy Cycurion equity holders would have held approximately 37.9% of the resulting company on an otherwise fully
diluted basis (but excluding the equity from the Relevant Financings).

 · Post-Relevant Financings and with 9.5 million shares to be issued
at the closing, the legacy Cycurion equity holders would have held approximately 18.5% of the resulting company on a fully diluted basis
(including the equity from the Relevant Financings).

 · Pre-Relevant Financings and with 12 million shares to be issued
at closing, the legacy Cycurion equity holders would have held approximately 43.6% of the resulting company on an otherwise fully diluted
basis (but excluding the equity from the Relevant Financings).

 · Post-Relevant Financings and with 12 million shares to be issued
at closing, the legacy Cycurion equity holders would have held approximately 22.2% of the resulting company on a fully diluted basis (including
the equity from the Relevant Financings).

As
a result of the issuance of the additional 2.5 million shares (after taking into account the dilutive effects of the Relevant Financings),
the legacy Cycurion equity holders will have offset the dilutive effects of the Relevant Financings and will have increased their fully
diluted percentages by approximately 3.7% (22.2% - 18.5%). That increase is mitigated by the dilution resulting from the closing of the
SLG Acquisition and the related RCR transaction.

Further,
during the period between the date of the original Business Combination Agreement and the date on which the parties agreed to the increase
in the prospective closing issuance from 9.5 million to 12 million shares of the Company’s capital stock, Cycurion’s
business prospects have improved and its revenues have increased. Such increase, when coupled with the reasons set forth above, provided
further comfort to the parties for the increase in the Merger Consideration.

As
noted in the Amendment No. 4, “[c]hanges in the operations and prospects of Cycurion, its interim financing needs, and general
market and economic conditions, and other factors upon which ValueScope’s opinion was based, may have significantly altered the
value of Cycurion from the date of the ValueScope opinion. Accordingly, that opinion was not relied upon by Western’s Board and
may not be relied upon by stockholders in deciding whether to approve the Business Combination. Western’s Board determined to approve
the Amended and Restated Business Combination Agreement without a fairness opinion and based upon their own experience in evaluating acquisition
opportunities.” With this background, the Company’s Board of
Directors continues to acknowledg