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August 7, 2023
Juan Fernandez Pascual
Chief Executive Officer, Secretary and Director
Aimei Health Technology Co., Ltd.
10 East 53rd Street, Suite 3001
New York, NY 10022
Re:Aimei Health Technology Co., Ltd.
Amendment No. 1 to Registration Statement on Form S-1
Filed July 24, 2023
File No. 333-272230
Dear Juan Fernandez Pascual:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, 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 comments apply 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 these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our June 21, 2023 letter.
Amendment No. 1 to Registration Statement on Form S-1 filed July 24, 2023
Redemption Rights, page 18
1.We note that the Amended and Restated Articles of Association filed as Exhibit 3.2
include a provision at Article 35.5(c) that you may limit redemptions to ensure that you
will have net tangible assets of at least $5,000,001 immediately prior to or upon an initial
business combination, after payment of underwriting fees and commissions. Please
describe this limitation here and where similar disclosure appears in the prospectus.

 FirstName LastNameJuan Fernandez Pascual
 Comapany NameAimei Health Technology Co., Ltd.
 August 7, 2023 Page 2
 FirstName LastName
Juan Fernandez Pascual
Aimei Health Technology Co., Ltd.
August 7, 2023
Page 2
If we seek shareholder approval of our business combination . . ., page 29
2.We note your disclosure in this risk factor indicating that any acquired public shares will
be voted as contemplated by Question 166.01 of the Division's Tender Offers and
Schedules C&DI. Rather than simply referring to the C&DI, please include narrative
disclosure explaining that securities purchased by the sponsor or its affiliates would not be
voted in favor of approving the business combination, and reconcile conflicting statements
such as that affiliated purchasers "may influence a vote in favor of a proposed business
combination" and that the purpose of the purchases would be to "increase the likelihood of
obtaining shareholder approval."
PRC Approvals, page 88
3.We note your disclosure here and elsewhere that you do not believe you are required to
obtain any permissions or approvals from the CRSC, CAC or any other governmental
entity to issue securities or list on a U.S. exchange. Clarify whether any permissions or
approvals are required to search for a target company. Please also explain the basis for
your conclusion that no permissions or approvals are required. If your conclusion is based
on an opinion of counsel, please file the opinion as an exhibit to the registration statement.
Certain Relationships and Related Party Transactions, page 111
4.We note your response to comment 9 and we reissue it.  Please revise to clarify how Arc
Group Limited is a related party.  For example, clarify whether there Arc Group officers,
directors or shareholders who also are also officers, directors or shareholders of the
company or the sponsor.
Enforcement of Civil Liabilities in Hong Kong and China, page 121
5.Please identify the independent director who is a resident of the PRC, here and where
similar disclosure appears in the prospectus. See prior comment 10.
General
6.As requested in prior comment 12, please include disclosure addressing the impact that
PRC law or regulation may have on the cash flows associated with the business
combination, including shareholder redemption rights.

 FirstName LastNameJuan Fernandez Pascual
 Comapany NameAimei Health Technology Co., Ltd.
 August 7, 2023 Page 3
 FirstName LastName
Juan Fernandez Pascual
Aimei Health Technology Co., Ltd.
August 7, 2023
Page 3
            You may contact Mark Rakip at 202-551-3573 or Wilson Lee at 202-551-3468 if you
have questions regarding the financial statements and related matters.  Please contact Ronald
(Ron) E. Alper at 202-551-3329 or Pam Long at 202-551-3765 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Andrei Sirabionian