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CORRESP
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CORRESP

 November 22, 2022

VIA EDGAR

United States Securities and Exchange Commission

 Division of
Corporation Finance

 Office of Life Sciences

 100 F Street
NE

 Washington, D.C. 20549

 White & Case
LLP

 555 South Flower Street

 Suite 2700

Los Angeles, California 90071-2433

 T +1 213 620 7700

 whitecase.com

Attn:
 Tyler Howes

Re:
 Apollomics Inc.

Draft Registration Statement on Form F-4

Submitted September 29, 2022

CIK No. 0001944885

 Mr. Howes:

 On behalf of our client, Apollomics Inc., a Cayman Islands exempted company (the “Company”), we are writing to submit
the Company’s responses to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “SEC”) with respect to the above-referenced
draft registration statement on Form F-4 submitted on September 29, 2022 (the “Draft Registration Statement”), contained in the Staff’s letter dated October 26, 2022 (the
“Comment Letter”).

 The Company has filed via EDGAR its first Registration Statement on Form F-4 (the “Registration Statement”), which reflects the Company’s responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained
in the Comment Letter is printed below in bold and is followed by the Company’s response. All page references in the responses set forth below refer to page numbers in the Registration Statement. Capitalized terms used but not defined herein
have the meanings set forth in the Registration Statement.

 Draft Registration Statement on Form F-4 submitted
September 29, 2022

 Cover Page

1.
 We note your disclosure that you face various legal and operational risks associated with doing business in
China. Please revise to make clear whether these risks could cause the value of your securities to significantly decline or be worthless. Please also revise your disclosure to address how recent statements and regulatory actions by China’s
government, such as those related to data security and anti-monopoly concerns, have or may impact Apollomics’ ability to conduct its business, accept foreign investments, or list on a U.S. or other foreign exchange.

Response: The Company acknowledges the Staff’s comment and has revised the disclosure on the cover page of the Registration
Statement.

 November 22, 2022

2.
 Clearly disclose how you will refer to the holding company and subsidiaries when providing the disclosure
throughout the document so that it is clear to investors which entity the disclosure is referencing and which subsidiaries or entities are conducting the business operations. Additionally, revise your diagram of the structure of Apollomics following
the business combination on page 27 to briefly describe the operations of your subsidiaries.

 Response: In
response to the Staff’s comment, the Company has revised the disclosure on the cover page of the Registration Statement to disclose how the Company refers to the holding company and subsidiaries throughout the Registration Statement and which
subsidiaries are conducting the Company’s business operations. The Company has also revised the diagram of the structure of the Company before and following the Business Combination by adding clarifying notes on pages 28 and 29 to briefly
describe the operations of the Company’s subsidiaries.

3.
 Please provide a description of how cash is transferred through your organization and disclose your
intentions to distribute earnings. State whether any transfers, dividends, or distributions have been made to date between the holding company and its subsidiaries, or to investors, and quantify the amounts where applicable. Provide a
cross-reference to the consolidated financial statements.

 Response: In response to the Staff’s comment,
the Company has provided the requested disclosure and a cross-reference to the consolidated financial statements on the cover page of the Registration Statement.

4.
 We note your disclosure that the Statement of Protocol with the CSRC and the Ministry of Finance of the
People’s Republic of China establishes a framework for the PCAOB to conduct inspections and investigations of PCAOB-registered public accounting firms in mainland China and Hong Kong. Please revise to also disclose that the PCAOB will be
required to reassess its determinations by the end of 2022.

 Response: In response to the Staff’s
comment, the Company has revised the disclosure on the cover page of the Registration Statement to disclose that the PCAOB will be required to reassess its determinations by the end of 2022.

Industry and Market Data, page 2

5.
 We note your disclosure that industry publications, research, studies and forecasts generally state that the
information they contain has been obtained from sources believed to be reliable, but that the accuracy and completeness of such information is not guaranteed. This statement implies a disclaimer of responsibility for this information in the
registration statement. Please either revise this section to remove such implication or specifically state that you are liable for all information in the registration statement.

Response: The Company acknowledges the Staff’s comment and has removed such statement.

 2

 November 22, 2022

 Questions and Answers About the Proposals

Q. What conditions must be satisfied to complete the Business Combination?, page 18

6.
 Please revise to identify the conditions that the parties may waive and still proceed with the business
combination, as you have done on page 174.

 Response: In response to the Staff’s comment, the Company has
revised the disclosure on pages 18 and 19 of the Registration Statement to identify the conditions that the parties may waive and still proceed with the Business Combination.

Q. How will the Sponsor and Maxpro’s officers and directors vote in connection with the Stockholder Proposals?, page 23

7.
 Please disclose if any consideration was received by the Sponsors in connection with their agreement to vote
their shares in favor of the business combination agreement.

 Response: In response to the Staff’s
comment, the Company has revised the disclosure on pages 23 and 24 of the Registration Statement.

 Q. May the Sponsor or Maxpro’s directors,
officers or advisors, or their affiliates, purchase shares in connection..., page 24

8.
 We note the statement that the Sponsors and their affiliates may purchase shares and/or warrants with the
purpose of voting them in favor of the Business Combination. Please provide your analysis on how such purchases would comply with the requirements of Rule 14e-5. Consider the guidance provided by Tender Offer
Rules and Schedules Compliance and Disclosure Interpretation Question 166.01 in your response.

 Response: The
Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 23, 24 and 25 of the Registration Statement to reflect the Staff’s guidance in Tender Offer and Schedules CDI Question 166.01.

Summary of the Proxy Statement/Prospectus

 Apollomics,
page 25

9.
 Please revise your summary to provide more background on Apollomics’ business including a more complete
discussion of the development status of your products. Please also discuss any steps you must take before commercialization of your product candidates.

Response: In response to the Staff’s comment, the Company has revised the disclosure on pages 26 - 27 of the Registration
Statement.

 3

 November 22, 2022

10.
 Clearly identify the entity in which investors hold their interest and the entities in which the
company’s operations are conducted.

 Response: In response to the Staff’s comment, the Company has
revised the disclosure on pages 27 - 29 and page 41 of the Registration Statement.

11.
 Disclose that trading in your securities may be prohibited under the Holding Foreign Companies Accountable
Act if the PCAOB determines that it cannot inspect or investigate completely your auditor, and that as a result an exchange may determine to delist your securities. Disclose whether your auditor is subject to the determinations announced by the
PCAOB on December 16, 2021.

 Response: In response to the Staff’s comment, the Company has provided
the requested disclosure on page 43 of the Registration Statement.

 Structure of Apollomics Before the Business Combination, page 26

12.
 Please revise your disclosure to affirmatively state, if true, that Apollomics’ corporate structure
contains no variable interest entities.

 Response: In response to the Staff’s comment, the Company has
revised the disclosure on the cover page and on pages 28, 29 and 41 of the Registration Statement to affirmatively state that the Company’s corporate structure contains no variable interest entities.

13.
 Provide a clear description of how cash is transferred through your organization. Disclose your intentions
to distribute earnings. Quantify any cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries, and the direction of transfer. Quantify any dividends or distributions that a subsidiary has
made to the holding company and which entity made such transfer, and their tax consequences. Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax consequences. Your disclosure should make clear if no
transfers, dividends, or distributions have been made to date. Describe any restrictions on foreign exchange and your ability to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations on your
ability to distribute earnings from the company, including your subsidiaries, to the parent company and U.S. investors. Additionally, disclose if you have specific cash management policies that dictate how funds are transferred through your
organization and if applicable, describe such policies and procedures.

 Response: In response to the
Staff’s comment, the Company has provided the requested disclosure on pages 41 - 43 of the Registration Statement and added cross references to such disclosure on pages 28 and 30 of the Registration Statement.

PRC Regulatory Approvals, page 34

14.
 Please revise your disclosure to state affirmatively whether you have received all requisite permissions or
approvals and whether any permissions or approvals have been denied. We note your disclosure that you relied on the advice of PRC counsel JunHe LLP. Please file the consent of counsel as an exhibit to the registration statement.

 Response: In response to the Staff’s comment, the Company has revised the disclosure on pages 40 and 173
of the Registration Statement and has filed the consent of the PRC counsel JunHe LLP as an exhibit to the Registration Statement.

 4

 November 22, 2022

 Summary of Certain Risk Factors, page 38

15.
 In your summary of risk factors, disclose the risks that your corporate structure and being based in or
having the majority of the company’s operations in China poses to investors. In particular, describe the significant regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion of these risks in the
prospectus. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice;
and the risk that the Chinese government may intervene or influence your operations at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers, which could result in a material change in
your operations and/or the value of the securities you are registering for sale. Acknowledge any risks that any actions by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or foreign
investment in China-based issuers could significantly limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless. For each summary
risk factor, provide a cross reference to the corresponding risk factor in the risk factors section.

Response: In response to the Staff’s comment, the Company has revised the disclosure on pages 44 - 46 of the Registration
Statement. We respectfully advise the Staff that adding individual cross-references for each corresponding risk factor would necessarily lengthen the summary risk factor disclosure to greater than two pages in length, a requirement under Item 105 of
Regulation S-K, without removing the summary risk factors arguably most material to investors. In addition, we respectfully advise the Staff that the disclosure on pages 44 and 46 should provide sufficient and
customary disclosure to guide an investor to the location of each corresponding risk factor in the Risk Factors section of the Registration Statement.

16.
 Please relocate your discussion of risks related to your operations in China to the beginning of this
section and make a corresponding change in your risk factors section. In your revisions, consider separating the risks highlighted here into distinct sections, as you have done in your risk factors section.

Response: In response to the comment of the Staff, the Company has relocated the discussions of risks related to its operations in China
to the beginning of this section and has made a corresponding change to the risk factors section. The Company has also separated such risks into distinct sections.

Risks Related to Doing Business in China, page 102

17.
 We note that your definition of “China” and “PRC” on page 3 excludes Hong Kong, Macau
and Taiwan for the purposes of your Proxy Statement/Prospectus. Please revise to clarify, where appropriate, that the legal and operational risks of doing business in China also apply to operations in Hong Kong and Macau.

 5

 November 22, 2022

 Response: The Company acknowledges the Staff’s comment and has revised the
disclosure on pages 49 - 60 of the Registration Statement.

18.
 Given the Chinese government’s significant oversight and discretion over the conduct of your business,
please revise to highlight separately the risk that the Chinese government may intervene or influence your operations at any time, which could result in a material change in your operations and/or the value of the securities you are registering.
Also, given recent statements by the Chinese government indicating an intent to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers, acknowledge the risk that any such action
could significantly limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless.

Response: In response to the Staff’s comment, the Company has revised the disclosure on pages 49 - 52 of the Registration
Statement.

19.
 In light of recent events indicating greater oversight by the Cyberspace Administration of China (CAC) over
data security, particularly for companies seeking to list on a foreign exchange, please revise your disclosure to explain how this oversight impacts your business and to affirmatively state to what extent you believe that you are compliant with the
regulations or policies that have been issued by the CAC to date.

 Response: In response to the Staff’s
comment, the Company has revised the disclosure on pages 51 - 54 of the Registration Statement.

 Apollomics audit report to be included in our proxy
statement/prospectus was prepared by an auditor located in mainland China..., page 109

20.
 We note your disclosure about the Holding Foreign Companies Accountable Act. Update your disclosure to
reflect that the Commissio