SecProbe.io

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Faegre Drinker Biddle & Reath LLP

1500 K Street, N.W., Ste. 1100

Washington, DC 20005, USA

www.faegredrinker.com

April 30, 2025

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: John Kernan and Anu Dubey

    Re:
    Privacore PCAAM Alternative Growth Fund (the “Fund”)

    File Nos. 811-23960; 333-285134

Dear Mr. Kernan and Ms. Dubey,

The following responds to
the staff’s accounting and disclosure comments provided via telephone on March 19, 2025, and March 20, 2025, respectively, in connection
with your review of the registration statement (the “Registration Statement”) filed by the Fund on Form N-2 under the Investment
Company Act of 1940, as amended (“1940 Act”), and the Securities Act of 1933, as amended (“Securities Act”), on
February 21, 2025.

The Fund will make the changes
to its disclosure discussed below in a pre-effective amendment to the Fund’s Registration Statement (the “Amended Registration
Statement”).

For your convenience, we have
repeated each comment below, and the Fund’s responses follow the Staff’s comments. Capitalized terms not otherwise defined
herein have the meaning ascribed to them in the Registration Statement, unless otherwise indicated.

ACCOUNTING COMMENTS

Prospectus

Investment Objectives and Strategies —
Types of Investment Structures — Secondary Investment Funds (page 21)

 1. Comment: Please enhance the disclosure on page 21, which states that “Secondary investment
funds acquired at a discount may result in unrealized gains at the time the fund next calculates its NAV,” to clarify that this
would occur only to the extent that the acquisition price no longer is representative of the determinable fair value, which would justify
the use of NAV as a practicable expedient for fair value.

Response: In the Amended
Registration Statement, the Fund will add language clarifying that (added text underlined and bolded) “Secondary Investment
Funds acquired at a discount may result in unrealized gains at the time the Fund next calculates its NAV to the extent that the
Valuation Designee (as defined below) determines that the acquisition price is no longer representative of fair value and applies NAV
as a practical expedient for fair value following the Fund’s Pricing and Fair Valuation Policies and Procedures adopted by the Board.

General Comment

 2. Comment: We note that many portions of your filing containing financial information are
incomplete or to be updated by amendment, including audited financial statements and a related auditor consent. We may have additional
comments on such portions of the filing when you complete them in an amendment, on disclosures made in response to this letter, on information
supplied supplementally, or on exhibits added to any amendments.

Response: The Fund will
update any missing information, respond to Staff comments, and file updated exhibits in the Amended Registration Statement. As discussed,
the Fund intends to raise its initial capital under Section 14(a)(3) of the 1940 Act and will (i) include with Parts A and B of the Amended
Registration Statement the Fund’s financial statements for the period from June 28, 2024 (commencement of operations) to December
31, 2024, which have been audited by PricewaterhouseCoopers LLP, the Fund’s independent registered public accounting firm and (ii)
undertake to file a post-effective amendment to the Registration Statement with certified financial statements showing the initial capital
received before accepting subscriptions from more than 25 persons.

DISCLOSURE COMMENTS

Prospectus

Cover Page

 1. Comment: Please include the legend required by Rule 481 under the Securities Act.

Response: Respectfully,
the legend required by Rule 481 under the Securities Act is already provided for in the last paragraph of the cover page. Accordingly,
the Fund has not made the requested change in the Amended Registration Statement.

 2. Comment: Confirm to us in the letter that the private offering of shares is no longer occurring
or explain to us why the private offering should not be integrated with public offering of fund shares under this Form N-2. See
Rule 152 under the Securities Act.

Response: The Fund
confirms that the private offering of shares has completed.

 3. Comment: Please include an offering table per Item 1.1.g of Form N-2.

Response: The Fund
will make the requested change in the Amended Registration Statement.

Prospectus
Summary – Question 1

 4. Comment: In the second paragraph of the answer which discusses the investment objective
of the Fund, please create another sentence for the second half of the sentence to reconcile the objectives that are disclosed on the
cover page.

Response: In response
to the Staff’s request at Comment 12 to consolidate the Prospectus Summary and Fund Summary into a single summary, the Fund has
removed the Q&A section from the Amended Registration Statement.

 5. Comment: The last sentence of the second paragraph of the answer states, “[t]he Fund’s
investments are expected to include:” If this is an existing operating fund, please delete “expected to.”

Response: In response to
the Staff’s request at Comment 12 to consolidate the Prospectus Summary and Fund Summary into a single summary, the Fund has removed
the Q&A section from the Amended Registration Statement.

 6. Comment: The first bullet point under the second paragraph of the
answer refers to “closed-end private funds.” Please confirm if this disclosure is referring to funds registered under the
1940 Act, or if it is referring to funds that are using an exclusion from the 1940 Act or both? Please clarify.

Response: In response
to the Staff’s request at Comment 12 to consolidate the Prospectus Summary and Fund Summary into a single summary, the Fund has
removed the Q&A section from the Amended Registration Statement. However, since the Staff’s comment applies as noted elsewhere
in the Amended Registration Statement, the Fund supplementally confirms that closed-end private funds or “Portfolio Funds”
as used in the Registration Statement, refers private funds that are excluded from the definition of “investment company”
under the 1940 Act.

 7. Comment: The fourth paragraph of the answer states the following: “The Fund aims to
provide a consolidated, diversified investment solution by pursuing investments in areas that might not be easily accessible
to individual investors…” [emphasis added] Please remove reference to diversified or add disclosure to explain what
diversified means in this context.

Response: In response to
the Staff’s request at Comment 12 to consolidate the Prospectus Summary and Fund Summary into a single summary, the Fund has removed
the Q&A section from the Amended Registration Statement. However, since the Staff’s comment applies as noted elsewhere in the
Amended Registration Statement, the Fund will remove “diversified” from the sentence in the Amended Registration Statement.

Prospectus
Summary – Question 2

 8. Comment: The sixth sentence in the first paragraph of the answer states that the “firm
is a joint venture...” Specify which entity the “firm” refers to by name.

Response: In response to
the Staff’s request at Comment 12 to consolidate the Prospectus Summary and Fund Summary into a single summary, the Fund has removed
the Q&A section from the Amended Registration Statement.

Prospectus Summary
– Question 5

 9. Comment: The second to last bullet point of the answer, states, in part, that the “Portfolio
will be deliberately allocated to …. greater return dispersion and offer premia for selection.” [emphasis
added]. Revise those words to be in plain English or explain what they mean. See Rule 421(b)(4) under the Securities Act.

Response: In response to
the Staff’s request at Comment 12 to consolidate the Prospectus Summary and Fund Summary into a single summary, the Fund has removed
the Q&A section from the Amended Registration Statement.

Prospectus Summary
– Question 8

 10. Comment: In the first bullet of the answer, briefly disclose what “real assets”
are.

Response:
In response to the Staff’s request at Comment 12 to consolidate the Prospectus Summary and Fund Summary into a single summary, the
Fund has removed the Q&A section from the Amended Registration Statement.

Prospectus Summary
– Question 11

 11. Comment: In reference to the second paragraph of the answer, please disclose that there
is no assurance that such exemptive relief will be granted.

Response:
In response to the Staff’s request at Comment 12 to consolidate the Prospectus Summary and Fund Summary into a single summary, the
Fund has removed the Q&A section from the Amended Registration Statement.

Fund Summary —
General Comment

 12. Comment: Please combine the prospectus summary and fund summary into a single summary. See
to Item 3.2 of Form N-2, which refers to “a synopsis.”

Response: The Fund
will make the requested change in the Amended Registration Statement.

Fund Summary — Investment
Objectives and Strategies (page 10)

 13. Comment: In the first sentence of the second paragraph, please change “objectives”
to “objective.”

Response: The Fund will
make the requested change in the Amended Registration Statement.

Fund Summary
— Fees and Expenses (page 11)

 14. Comment: The first sentence of this section states “[t]he Fund’s expenses incurred
and to be incurred in connection with the Fund’s organization are not expected to exceed $400,000.” Please review and update
this section, if necessary, given the Fund was organized last year.

Response: The Fund will
delete the referenced sentence in the Amended Registration Statement.

Summary of Fund
Expenses — Fee Table (pages 16-17)

 15. Comment: Please explain to us why the costs and charges will be disclosed under “Other
Expenses” in the fee table when they are being allocated only to repurchasing Shareholders rather than being incurred by the Fund
as an operating expense. Explain to us why the cost and charges are not being included in the line item showing the early withdrawal charges
in the fee table.

Response: In the Fund’s
response letter to Staff comments emailed on December 20, 2024, the Fund confirmed that other than the Early Repurchase Fee, that the
Fund does not presently intend to impose any charges on the repurchase of Shares. However, the Fund is permitted to allocate to Shareholders,
whose Shares are repurchased, costs and charges imposed by the Portfolio Funds, if the Adviser determines to liquidate such interests
as a result of repurchase tenders by Shareholders and such charges are imposed on the Fund. In the event that any such charges are allocated
to the Fund, and subject to applicable law, the Fund may allocate such charges to the Shareholders whose repurchase tenders resulted in
the repurchase of a portion of the Shares that resulted in such charges. The Fund confirms that such costs and charges will be appropriately
disclosed under “Maximum Early Repurchase Fee” in the fee table.

 16. Comment: In footnote 8 of the fee table, please disclose the date the expense limitation
agreement expires.

Response: The Fund will
make the requested change in the Amended Registration Statement.

Financial Highlights

 17. Comment: Confirm if this section is accurate given the disclosure on page 18 in the Statement
of Additional Information that says the financial highlights will be in the Fund’s annual report and that it is incorporated by
reference.

Response: Please see the
Fund’s response to Comment 2 above. With the Prospectus, the Fund will include audited financial highlights for the period from
June 28, 2024 (commencement of operations) to December 31, 2024. The Fund’s fiscal year end is March 31, and the Fund’s first
annual audit is underway. When complete, the Fund will file its annual report on Form N-CSR and file a post-effective amendment to the
Registration Statement that will incorporate by reference the Fund’s audited financial statements appearing in its March 31, 2025
annual report.

Investment Objectives and Strategies —
Target Asset Classes Overview — Private Real Estate (page 23)

 18. Comment: The last sentence of the first paragraph states, in part, that “returns may
be 100% dependent on the appreciation of the asset.” Provide an explanation as to what “returns may be 100%” means and
indicate what the percentage is based on.

Response: In the Amendment
Registration Statement, the Fund will revise the sentence as follows (added text underlined and bolded; deleted text stricken):

Ultimately, the returns
from investments in private real estate may be driven entirely by 100% dependent on the appreciation
of the asset due to the repositioning/renovations undertaken by the Portfolio Fund Manager and resulting expected cash flows for the properties
into the future.

General Risks — (page 29)

 19. Comment: Please use the word “principal” either in the heading of this section
or in the introduction paragraph to indicate, as disclosed on page 67, that these are principal risks. See Item 8.3.a. of Form
N-2.

Response: The Fund will
make the requested change in the Amended Registration Statement.

Management of the Fund — Investment Management
Agreement (page 70)

 20. Comment: In the last sentence of the second paragraph of this section,
please insert “bad faith” into this list.

Response: The Fund will
make the requested change in the Amended Registration Statement.

Distributor— (page 72)

 21. Comment: Tell us if FINRA will review distribution terms of this offering and if so, confirm
to us that Fund has received no objection letter from FINRA.

Response: The Fund confirms
that FINRA will review the distribution terms of this offering, and it has received no objection letter prior from FINRA.

 22. Comment: The eighth sentence of the third paragraph states that “[t]he Distributor
does not receive compensation from the Fund for its distribution services but may receive compensation for its distribution services from
the Adviser. Next, the second to last sentence of the same paragraph states that “[t]he Distribution and Service Plan allows the
Fund to pay distribution and servicing fees for the sale and servicing of its Class S Shares and Class D Shares to the Fund’s Distributor
and/or other qualified recipients.” Please reconcile.

Response: The Fund will
revise the disclosure as follows in the Amended Registration Statement (added text underlined and bold; deleted text stricken):

“[t]he Distributor does not receive
compensation from the Fund aside from distribution and servicing fees paid pursuant to the Distribution and Service Plan
for its distribution services. but The Distributor may receive compensation for its distribution services
from the Adviser.”

Outstanding Securities — (page
81)

 23. Comment: Response 35 in the Fund’s August 2024 letter responding
to Staff comments describes the Fund’s seed investors. Please tell us who the unaffiliated seed investors are in addition to Janus
Henderson.

Response: The Fund’s
unaffiliated seed investors are individuals and family offices who had a pre-existing relationship with Partners Capital or were introduced
to Partners Capital through its network.

Repurchase Procedure — (pages
84-86)

 24. Comment: Rule 14e-8 under the Securities Exchange Act of 1934 prohibits announcements of
tender offers without the intention to commence such offers within a reasonable time. Please revise the registration statement to limit
the discussion of tender offers to general information such as how tender offers will be funded, any general frequency of tender offers
(i.e., quarterly, semi-annually, annually, etc.), the effect that share repurchases and related financings might have on expense ratios
and portfolio turnover, the ability of the Fund to achieve its investment objectives, and potential tax consequences to investors. We
believe that specific procedures that the Fund currently intends to follow at the t