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            CLIFFORD CHANCE US LLP

            31 WEST 52ND STREET

            NEW YORK, NY 10019-6131

            TEL +1 212 878 8000

            FAX +1 212 878 8375

            www.cliffordchance.com

            November 8, 2023

    Securities and Exchange Commission

    Division of Corporation Finance

    Office of Real Estate & Construction

    100 F Street, NE

    Washington, DC 20549

            Attn:

            Eric McPhee

            Wilson Lee

            Ronald (Ron) E. Alper

            Pam Howell

          Re:

            Murano Global Investments Ltd

              Amendment No. 1 to Registration Statement on Form F-4

              Filed October 10, 2023

              File No. 333-273849

    Ladies and Gentlemen:

    This letter responds to the comment letter (the “Comment Letter”) of the staff (the “Staff”) of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Commission”),

      dated October 26, 2023, to Mr. Elías Sacal Cababié, Chief Executive Officer of Murano Global Investments Limited (the “Company”) regarding the Registration Statement and Proxy Statement on Form F-4 filed on October 10, 2023 (the “Registration

        Statement”). Simultaneously with the submission of this letter, the Company is filing Amendment No. 2 to the Registration Statement on Form F-4 (the “Amended Registration Statement”), which reflects changes made in response to certain of
      the comments contained in the Comment Letter and certain other changes.

    This letter sets forth each comment of the Staff in the Comment Letter and, following the comment, sets forth the Company’s response.

    Cover Page

              1.

              We partially reissue prior comment 2. Please provide the information required by Item 2(1) and (2) of Form F-4 on the inside front cover page.

    The Company respectfully acknowledges the Staff’s comment and the Company has revised the disclosure on the inside cover page of the Amended Registration Statement.

              2.

              Please reconcile the amount of ordinary shares, warrants and ordinary shares underlying the warrants disclosed on the cover page with the amount
                reflected in the exhibit table in Exhibit 107.

    The Company respectfully acknowledges the Staff’s comment and the Company has revised the disclosure on the inside cover page of the Amended Registration Statement.

     Page 2 of 6

        November 8, 2023

    Questions and Answers About the Business Combination and the Extraordinary Meeting, page 11

              3.

              We note your response to prior comment 8; however, we do not see disclosure in the table regarding dilution to the HCM public
                  shareholders. Please add disclosure showing how the shares owned by HCM public shareholders may be diluted.

    The Company respectfully acknowledges the Staff’s comment and the Company has revised the disclosure on pages 16-17 of the Amended Registration Statement.

              4.

              We reissue prior comment 12. Revise your disclosure to show the potential impact of redemptions on the per share value of the shares owned by the non-redeeming
                shareholders by including a sensitivity analysis showing a range of redemption scenarios, including minimum, maximum and interim redemption levels.

    The Company respectfully acknowledges the Staff’s comment and the Company has revised the disclosure on pages 16-17 and 36-37 of the Amended Registration Statement.

              5.

              Please revise the table on page 1 reflecting the effective fees payable to the underwriter on a percentage basis based on the level of redemptions to reflect 75% and 90%
                redemptions. Similarly revise the disclosure regarding the impact of redemptions on underwriting fees as a percentage of the HCM stock price to reflect 75% and 90% redemptions.

    The Company respectfully acknowledges the Staff’s comment and the Company has revised the disclosure on pages 15, 83, and 159 of the Amended Registration Statement.

              6.

              We reissue prior comment 5. Please disclose on page 15 when discussing the equity stake current HCM Holders and Murano Shareholders will have in PubCo after the Closing
                and elsewhere in the prospectus where similar disclosure is provided the sponsor and its affiliates’ total potential ownership interest in the combined company, assuming exercise and conversion of all securities.

    The Company respectfully acknowledges the Staff’s comment and the Company has revised the disclosure on pages 16-17 and 37 of the Amended Registration Statement.

              7.

              We partially reissue prior comment 6. Please quantify the aggregate dollar amount of what the sponsor and its affiliates have at risk that depends on completion of a
                business combination. Please also disclose the value of the common stock underlying the private warrants held by Cantor Fitzgerald.

    The Company respectfully acknowledges the Staff’s comment and the Company has revised the disclosure on pages 19-20, 34-35, 111-112, and 156 of the Amended Registration Statement.

    Material US Federal Income Tax Considerations, page 129

              8.

              We partially reissue prior comment 18. We note your response that you clearly disclose this will be a taxable event. However, we note that you continue to state that you
                intend for the transactions to qualify as a transaction described in Section 351(a) and thus not a taxable transaction. We also note continued disclosure that you intend for the transaction to qualify as a “reorganization” under Section 368
                but that this is highly uncertain. Lastly, you do not reach the conclusion that this will be a taxable event for shareholders. Instead, you state that “it may be prudent for a US holder that does not have in effect a valid QEF election ...
                to assume that the Business Combination is treated as a taxable transaction.” Please revise to clearly disclose the material tax consequences of the transaction and to the extent you continue to disclose that the transaction may be tax
                free, attribute the tax opinion to named counsel and file the tax opinion as an exhibit. Please also remove any statement that assumes the material tax consequences at issue (e.g., “The remainder of this discussion is based upon the
                position that the Merger qualifies as a transaction described in Section 351(a) of the Code”). Refer to Section III of Staff Legal Bulletin No. 19 for guidance.

        The Company has revised the Amended Registration Statement in response to the Staff’s comment. Please see pages 22, 90, and 132-133 of the Amended Registration Statement. In
          addition, the Company has filed an opinion of Clifford Chance US LLP as Exhibit 8.1 to the Amended Registration Statement.

    Page 3 of 6

        November 8, 2023

    Proposal No. 1: The Business Combination Proposal Background of the Business Combination, page 140

              9.

              We reissue prior comment 23. Please revise your disclosure throughout this section to provide greater detail as to how the material terms of the transaction structure
                and consideration evolved during the negotiations.

    The Company respectfully acknowledges the Staff’s comments and the Company has revised the disclosure on pages 144-145 and 147-148 of the Amended Registration Statement to provide
      detail regarding the negotiations concerning the forfeiture of 1,250,000 Founder Shares and all of HCM’s Private Placement Warrants and the disclosures on page 145 of the Amended Registration Statement to make clear that HCM consulted with its tax
      advisor to ensure that the change to structure requested by the Company would not negatively impact HCM’s shareholders.  Otherwise, the Company respectfully submits that the description accurately reflects the material discussions regarding the
      material terms of the transaction structure and consideration during the course of negotiations.  As noted in the section entitled “Background of the Business Combination,” the parties discussed an initial
      equity value of $650 million for Murano, with the exclusive consideration in the transaction being newly issued shares of PubCo.  Such structure and valuation was expressly subject to due diligence, which occurred over the course of the next several
      months, as detailed in the “Background of the Business Combination”.  The ongoing due diligence process was used to confirm the equity value for the Company (as described in the “Background of the Business Combination”, as is the duration of such due diligence process related to obtaining appropriate financial statements), which was eventually determined to be $690.9 million (as reflected on page 210 of the
      Amended Registration Statement).  Furthermore, the “Background of the Business Combination” makes clear that the Business Combination Agreement was drafted to provide HCM ongoing access to due diligence to
      continue to monitor the agreed upon equity value for the Company.  Also as detailed in the “Background of the Business Combination,” the Company and its owners sought certain flexibility to implement certain
      internal restructuring transactions for reasons of tax optimization.  As noted in the “Background of the Business Combination,” HCM negotiated a right to approve all such steps the Company might propose to
      take in connection with such internal restructuring.

    HCM’s Board of Directors’ Recommendation of and Reasons for the Business Combination, page 146

              10.

              We reissue prior comment 26. Please discuss what consideration, if any, the board gave in the August 1, 2023 reaffirmation of the recommendation of approval of the business
                combination to the significant redemptions that occurred in the April 2023 extension.

    The Company respectfully acknowledges the Staff’s comment and the Company has revised the disclosure on pages 147-148 of the Amended Registration Statement.  The Company also
      notes that it had previously included similar disclosure in the section entitled “The HCM Board of Directors’ Recommendation of and reasons for the Business Combination”.

    Summary of HCM Financial Analysis Materials of HCM’s Financial Advisor, page 149

              11.

              We note your response to prior comment 27. Please clarify whether and how the board considered the unaudited prospective financial information of Murano in considering the
                transaction or the fairness determination. To the extent the board did not consider such information in considering the transaction or the fairness determination, please clarify how the financial information was used, whether this financial
                information was specifically requested and how this information relates to the consideration. Similarly, discuss how such financial information was used by HCM’s Financial Advisor. We note the removal of the disclosure that CCM reviewed the
                financial projections.

    The Company respectfully submits that certain unaudited prospective financial information was requested as part of HCM’s ordinary course diligence process and was reviewed by HCM
      and its advisors in concert with its due diligence regarding new hotels in the relevant geographic markets but was not otherwise given considerable weight by HCM management or its board in its consideration of the transaction, each of which focused
      more on the value of the Company’s assets and their potential value following completion of construction by reference to multiples of value attributed to hotel room key-counts in comparable markets.

       Page 4 of 6

        November 8, 2023

              12.

              We note your response to prior comment 30 that the CCM Materials were an investor presentation drafted on a collaborative basis amongst the Murano, HCM and each of their
                respective professional advisors. Please reconcile with the disclosure in this section which indicates the CCM Materials were presented to HCM’s board and that such information was obtained from Murano and approved for use by HCMs board or
                from third party sources. To the extent this was information presented to HCM’s board, please provide your analysis as to whether the CCM Materials is a “report…materially relating to the transaction ... from an outside party.” If so,
                please provide the information required by Item 1015(b) of Regulation M-A and file such report as an exhibit. Refer to Item 4(b) of Form F-4.

    The Company acknowledges the Staff’s comment. Respectfully, the Company does not believe that CCM provided a report, opinion or appraisal within the meaning of Item 1015(b) of
      Regulation M-A, but rather that CCM provided customary assistance to HCM’s management in conducting its own financial analysis, which is summarized beginning on page 152 of the Amended Registration Statement.  The Company specifically notes that CCM
      was not retained to render a fairness opinion, and did not render a fairness opinion, in connection with the transaction.  The Company has included descriptions of the presentations made to the HCM board by CCM during the deliberations as part of the
      HCM board’s record of compliance with its fiduciary duties and not because the HCM board believes that it has received reports, opinions or appraisals relating to these subjects within the meaning of Item 1015 of the Regulation M-A or Item 9 of Form
      F-4.  Indeed, under CCM’s engagement letter, HCM is expressly responsible for information provided to CCM, which includes the contents of the CCM Materials.

              13.

              We reissue prior comment 31. We note that CCM was retained as a financial advisor to HCM. Please clearly describe the role of CCM in the de-SPAC transaction, and the level
                of diligence the financial advisor performed in connection with the transaction.

    The Company respectfully submits that the description provided in the section entitled “Background of the Business Combination – Summary of HCM
        Financial Analysis – Materials of HCM’s Financial Advisor” accurately reflects CCM’s role in the business combination transaction, which was to assist with financial due diligence and provide related financial advice.

    Interests of Certain HCM Persons in the Business Combination, page 152

              14.

              We reissue prior comment 32. Please revise your disclosure to explain how such purchases would comply with the requirements of Rule 14e-5 under the Exchange Act. Refer to
                Tender Offer Rules and Schedules Compliance and Disclosure Interpretations 166.01 for guidance.

    In response to the Staff’s comments, and while no privately negotiated transaction are currently contemplated, the Company has revised its disclosures on pages 18 and 157 of the
      Amended Registration Statement to appropriately reflect the terms in reliance on Tender Offer Compliance and Disclosure Interpretation 166.01.

    Business of Murano and Certain Information About Murano, page 160

              15.

              We reissue prior comment 35. Please provide the disclosure required by Item 4.D. of Form 20-F regarding your properties, as required by Item 14(b) of Form F-4. When
                discussing the current development projects please disclose the current status of each project development, the estimated costs of each development, and the impact upon the estimated timing to the extent financing is not obtained.

    The Company respectfully acknowledges the S