SecProbe.io

February 18, 2025
I-Fa Chang
Sole Director
Aimfinity Investment Merger Sub I
c/o Docter Inc.
14F-7, 597 Jiuru 2nd Rd
Sanmin District
Kaohsiung City, Taiwan
Hsin-Ming Huang
Chief Executive Officer
Docter Inc.
14F-7, 597 Jiuru 2nd Rd
Sanmin District
Kaohsiung City, Taiwan
Re:Aimfinity Investment Merger Sub I
Registration Statement on Form F-4
Filed February 3, 2025
File No. 333-284658
Dear I-Fa Chang and Hsin-Ming Huang:
            We have reviewed your registration statement and have the following comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our December 17, 2024
letter.

February 18, 2025
Page 2
Registration Statement on Form F-4
Background of the Business Combination, page 107
1.We note your response to comments 4 and 5, and your disclosure on page 114 that
Docter "agreed to refine and reduce its projections provided in the initial valuation in
terms of potential sales benchmarks, size of potential markets and growth rate." Please
advise whether the financial projections disclosed on page 125 are the revised
projections reflecting these recommendations, and if so, please further revise your
disclosures on page 126 to provide a detailed discussion of any material changes from
the initial projections prepared by Docter and shared by Mr. Huang in June 2023,
including but not limited to the number of products expected to be sold, the unit price
for such sales, and projected addressable markets and market sizes.
2.We note your disclosure on page 118 that "[f]ollowing separate discussions by and
among Mr. Chang, Mr. Tian, Aimfinity’s CFO, Mr. Huang, and Mr. Guo between
December 13 to December 16, 2024, Docter engaged Mr. Guo on [December] 22,
2024 as the financial advisor of Docter, who was tasked with the role to assist Mr.
Huang in the preparation of updated projections of Docter’s financial performance for
fiscal years ended December 31, 2024 through December 31, 2034." Please disclose
whether Mr. Guo was paid any fees in connection with his role as financial advisor to
Docter.
3.We note your disclosure on page 118 that "[o]n January 8, 2025, Mr. Guo shared the
updated financial projections of Docter for the fiscal years ended December 31, 2024
through December 31, 2034 to Mr. Chang and Mr. Tian," and that "the Aimfinity
management decided to recommend to the Board that, based on the updated financial
projections of Docter, Aimfinity should consider not to propose any change to the
merger consideration of $60M." Please revise to discuss the factors underlying
Aimfinity management's decision to recommend to the board that they should not
consider any changes to the merger consideration.
Basis for the Recommendation of Aimfinity's Board of Directors -- Fairness Opinion, page
127
4.We note your disclosure on page 119 that "[o]n January 29, 2025, Newbridge
delivered an updated Fairness Opinion and presentation to the Aimfinity Board, which
considered, in part, the updated projections of profit and loss provided by Docter as of
January 27, 2025... [and] provided, subject to its terms, assumptions and limitations,
in relevant part, that the merger consideration of $60 million remain fair from a
financial perspective to the unaffiliated shareholders of Aimfinity." Please revise,
either on page 119 or under your discussion of the fairness opinion starting on page
127, to provide a detailed explanation of how Newbridge considered the revised
projections by Docter, and how they concluded that the revised projections did not
impact their opinion that the $60 million valuation for Docter is fair from a financial
perspective to unaffiliated shareholders of Aimfinity.

February 18, 2025
Page 3
Certain Engagements in Connection with the Business Combination and Related
Transactions, page 131
5.We note your amended disclosure that "[o]n November 22, 2024, US Tiger sent a
notice to Aimfinity to notify of its intent to terminate the Business Combination
Marketing Agreement and cease its involvement in the Business Combination.
However, the Business Combination Marketing Agreement requires mutual consent
for the termination of the agreement and Aimfinity has not agreed to terminate the
agreement." Please revise to briefly discuss why US Tiger ceased its involvement in
the business combination and clarify whether Aimfinity plans to consent to terminate
the agreement. Please also disclose any risks related to US Tiger's intent to terminate,
if material.
Business Of Docter
Our Customers, page 146
6.We note your disclosure on page 148 that "in August of 2023, Docter entered into a
memorandum of cooperation (the “MOC”) with the Innovation Center for
Computational Health, Massachusetts General Hospital, Harvard Medical School (the
“Innovation Center”), pursuant to which Docter provided a small number of
DocterWatches to the Innovation Center in connection with its preliminary study and
clinical trial in Taiwan studying Myalgic encephalomyelitis/chronic fatigue syndrome
(“ME/CFS”) and long COVID (the “Taiwan Clinical Trial”)." Please revise to
disclose any material, commercial terms pursuant to the MOC with the Innovation
Center and file the MOC as an exhibit to the registration statement. Refer to Item
601(b)(10) of Regulation S-K.
General
7.We note that your fee table includes disclosure that you are registering the "up to
150,000 PubCo Ordinary Shares issuable to the Sponsor or its designees or affiliates,
upon conversion of certain working capital notes or extension notes Aimfinity
Investment Corp. I issued to the Sponsor or its designees or affiliates." We also note
your disclosure that the working capital notes and monthly extension notes were
issued pursuant to the exemption from registration contained under Section 4(a)(2) of
the Securities Act.  Please provide us your analysis regarding why it is appropriate to
register these securities as a primary issuance on this registration statement, or remove
these shares from your registration statement. Please refer, in part, to Securities Act
Sections Compliance and Disclosure Interpretations 134.03 and 139.09.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

February 18, 2025
Page 4
            Please contact Christie Wong at 202-551-3684 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related
matters. Please contact Juan Grana at 202-551-6034 or Katherine Bagley at 202-551-2545
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Ze'-ev D. Eiger, Esq.
Michael J. Blankenship, Esq.