SecProbe.io

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Faegre Drinker Biddle & Reath LLP

One Logan Square, Ste. 2000

Philadelphia, PA 19103

Telephone: (215) 988-2700

Facsimile: (215) 988-2757

www.faegredrinker.com

February 26, 2025

Via EDGAR Transmission

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Seamus O’Brien

    Re:
    Calamos Aksia Private Equity and Alternatives Fund (the “Fund” or “Registrant”)

Initial Registration Statement on Form N-2

File Nos. 333-283688, 811-24034

Dear Mr. O’Brien:

The following responds to
the comments provided via email on January 8, 2025, in connection with the Securities and Exchange Commission staff’s (the
 “Staff”) review of a registration statement (the “Registration Statement”) filed by the Fund on Form N-2
under the Investment Company Act of 1940, as amended (the “1940 Act”) and the Securities Act of 1933, as amended. The changes
to the Fund’s disclosure discussed below will be reflected in Pre-Effective Amendment No. 1 to the Fund’s Registration
Statement (the “Revised Registration Statement”).

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

General

 1. Comment: Where a comment is made with regard to disclosure in one location, it is applicable
to all similar disclosure appearing elsewhere in the registration statement.

Response:
The Registrant acknowledges and understands the Staff’s comment.

 2. Comment: We note that many portions of your filing are incomplete or to be updated by amendment.
We may have additional comments on such portions when you complete them in pre-effective amendments, on disclosures made in response to
this letter, on information supplied supplementally, or on exhibits added in any pre-effective amendment, such as the Fund’s organizational
documents.

Response:
The Registrant acknowledges and understands the Staff’s comment.

 3. Comment: Please tell us if you have presented any test the waters materials to potential
investors in connection with this offering. If so, we may have additional comments.

Response:
The Fund has presented test the waters material that was shared with Institutional Accredited Investors in order to assess their interest
in the possible offering.

 4. Comment: Please supplementally advise us if you have submitted or expect to submit any exemptive
application or no-action requests in connection with your registration statement, including with respect to multi-class and co-investment
relief.

Response:
The Registrant supplementally advises the Staff that it intends to offer multiple classes of shares pursuant to the exemptive relief granted
to Calamos-Avenue Management, LLC (File no. 812-15131, Notice No. 34300 (June 14, 2021), Order No. 34327 (Jul. 12,
2021)) (the “Multi-Class Order”). The Multi-Class Order may be relied upon by any “Future Fund” (as
defined in the Notice and application), and the Registrant is a Future Fund within the meaning of the Multi-Class Order. The Registrant
also advises the Staff that it intends to rely on the exemptive relief granted to Calamos Aksia Alternative Credit and Income Fund, et
al. (File no. 812-15448, Notice No. 34911 (May 8, 2023), Order No. 34936 (June 2, 2023)) to participate in certain
joint transactions that might otherwise be prohibited by Section 17(d) of the 1940 Act (the “Co-Investment Order”).
The Co-Investment Order may be relied upon by any “Future Regulated Entity” (as that term is defined in the application) and
the Registrant is a Future Regulated Entity within the meaning of the Co-Investment Order.

 5. Comment: Please confirm that any credit agreements the Fund has entered into or will enter
into prior to effectiveness will be filed as exhibits to the Registration Statement.

Response:
The Registrant respectfully advises the Staff that it does not believe the filing of credit agreements is required by Form N-2. Credit
agreements are not specifically referenced among the required exhibits listed in Item 25.2 of Form N-2. Item 25.2.k contains a catch-all
that requires “copies of all other material contracts not made in the ordinary course of business that are to be performed in whole
or in part at or after the date of filing the registration statement” to be filed as exhibits to the registration statement. Because
borrowings under any credit agreement that would be entered into by the Fund will be used to invest in additional securities, pay expenses, etc.
in accordance with the Fund’s investment objectives and strategies and the registration statement, the Fund considers credit agreements
to be agreements made in the “ordinary course of business.”

 6. Comment: On the facing sheet, please uncheck the box “when declared effective pursuant
to section 8(c) of the Securities Act,” as that section relates to post-effective amendments.

Response:
The requested change is reflected in the Revised Registration Statement.

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Cover Page

Pages i-iv

 7. Comment: The disclosure on page i references the reorganization of the Predecessor
Fund with and into the Fund. In correspondence, please provide additional information related to the reorganization, including whether
any exemptive relief is required in order to affect the reorganization. If you are relying on the GuideStone no-action letter, please
explain any differences and similarities between the facts underlying the reorganization of the Predecessor Fund into the Fund and those
in the Guidestone no-action letter. Please explain why the Predecessor Fund did not itself register as a fund and instead reorganized
into the Fund.

Response:
The reorganization of the Predecessor Fund into the Fund will comply with the conditions of the GuideStone Financial, et al., SEC No-Action
Letter (pub. avail. December 27, 2006). Pursuant to an Agreement and Plan of Reorganization, the Predecessor Fund will, at the time
of the reorganization, transfer all of its assets to the Fund in exchange for shares of the Fund. Consistent with the GuideStone Financial
no-action letter:

 1) The reorganization will comply with the terms of paragraphs (b), (c), (d), (e), (f) and (g) of
Rule 17a-7 under the 1940 Act and the provisions of Rule 17a-8 under the 1940 Act (which among other things, requires an independent
evaluator to value any assets to be transferred for which market quotations are not readily available);

 2) The Fund will be a shell portfolio as of the time of the reorganization;

 3) The assets of the Predecessor Fund will consist of securities that are appropriate, in type and amount,
for investment by the Fund in light of its investment objectives and policies;

 4) The Predecessor Fund will transfer all of its portfolio securities at the time of the reorganization to
the Fund;

 5) The Fund has the same procedures for determining net asset value as the Predecessor Fund and will follow
those procedures in determining the amount of shares to be issued in the reorganization;

 6) The transfer of securities and shares between the Predecessor Fund and the Fund will be effected simultaneously;

 7) The Fund will comply with the recordkeeping requirements described in the GuideStone Financial no-action
letter;

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 8) Each of the Advisor and the Sub-Advisor, consistent with its fiduciary duties, has disclosed to the independent
trustees of the Fund the existence of, and all the material facts relating to, any conflicts of interest between the Advisor and Sub-Advisor
and the Fund with regard to the reorganization to facilitate the ability of the independent trustees to evaluate and approve the reorganization;
and

 9) The Advisor and/or the Sub-Advisor, not the Predecessor Fund or the Fund, will bear the costs associated
with the reorganization.

The decision to reorganize the Predecessor
Fund into a shell registered investment company, rather than registering the Predecessor Fund directly as an investment company, is driven
by a business judgment that such a reorganization is the more efficient way to bring a private equity and alternatives focused interval
fund to market. Among other considerations, it would take longer to bring the Predecessor Fund to market in a registered fund format if
the Predecessor Fund registered directly instead of reorganizing into the Fund. Because the investment strategy is primarily illiquid
and sufficient time is needed to construct a portfolio able to meet various requirements of the 1940 Act and the Code, if the Predecessor
Fund registered directly, it would need to wait until its portfolio was fully assembled and able to meet 1940 Act and Code requirements
prior to filing a Form N-8A (or within a short period of time thereafter). Operating the Predecessor Fund and registering the Fund
in parallel allows the Predecessor Fund to continue to build its portfolio during the Fund’s registration process and up to the
time of the reorganization.

 8. Comment: Footnote (1) on page i suggests the initial investment minimum may be
waived for all classes of shares (emphasis added). Please confirm this is accurate and clarify the disclosure as applicable throughout
registration statement. We note, for example, disclosure on page 81 of the registration statement is unclear as to this point. Additionally,
please add a cross-reference in this footnote and in the Securities Offered sub-section on page ii of the cover page where such
waivers are mentioned and also in the Purchase Terms subsection on page 81 of the prospectus that discusses to whom such waivers
may be granted.

Response:
The requested revisions have been made in the Revised Registration Statement.

 9. Comment: On page ii where the Securities Offered sub-section, states, “. . .
except for purchases made pursuant to the Fund’s dividend reinvestment plan or as otherwise permitted by the Fund,” please
include a direct cross reference to the disclosure regarding this policy elsewhere in the registration statement.

Response:
The requested revision has been made in the Revised Registration Statement.

 10. Comment: The Principal Investment Strategies sub-section on page ii of the cover page,
states that, “[t]he Fund will seek to achieve its investment objective by primarily investing in private equity funds that employ
a variety of strategies including but not limited to buyout, growth equity and venture capital, and in other private equity related investments
including secondary market purchases of existing private equity fund interests and investments in private equity fund continuation vehicles
(“Private Equity Funds”) offered by third-party investment managers ("Underlying Managers”) and in the equity
and debt securities of private companies typically alongside Private Equity Funds (“Co-Investments”)” (emphasis added).
The Term “Private Equity Funds” appears to include secondary market purchases of private equity funds, yet in clause (i) of
the next paragraph immediately below, there's a reference to primary investments in private equity funds. Please review the definition
of Private Equity Funds for clarity and consider limiting the description to the type of vehicle.

Response:
The Registrant has revised the Principal Investment Strategies for clarity.

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 11. Comment: On page ii, please clarify that “Private Equity Funds” are commingled
asset pools that typically offer their securities privately, without registering such securities under the 1933 Act.

Response:
The Registrant confirms it has clarified the requested disclosure.

 12. Comment: Where the Interval Fund sub-section on page ii discusses quarterly repurchase
offers, please provide more specificity with respect to the anticipated timing of the fund's initial repurchase offer. See Guide 10 to
Form N-2.

Response:
The Registrant confirms the requested disclosure has been added to the Revised Registration Statement.

 13. Comment: The Registrant must state in its prospectus and SAI, that it will provide to each
person, including any beneficial owner, to whom a prospectus or SAI is delivered, a copy of any or all information that has been incorporated
by reference into the prospectus or SAI but not delivered with the prospectus or SAI. See, General Instruction F.4.(b)(1) to Form N-2.

Response:
The Registrant confirms the requested disclosure has been added to the Revised Registration Statement.

 14. Comment: In the third bullet point on page iv (and elsewhere where return of capital
distributions is discussed), please disclose the tax consequences of return of capital distributions.

Response:
The Registrant confirms the requested disclosure has been added to the Revised Registration Statement.

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Prospectus

Summary of Terms; Page 6-14

 15. Comment: Each sub-section of the Summary of Terms should include cross references to more
detailed disclosure in the Prospectus. Please add such cross references to the extent not already included or previously commented on.

Response:
The requested cross-references have been added to the Revised Registration Statement.

 16. Comment: In the Investment Opportunities and Strategies sub-section any catch-all language
such as “including, but not limited to” should be removed. The disclosure should address the Fund’s principal investment
strategies with specificity. Please make this change consistently throughout the Registration Statement in related sections.

Response:
The Registrant has updated the disclosure accordingly.

 17. Comment: Please confirm that unfunded commitments will not be counted toward the Fund’s
compliance with Rule 35d-1.

Response:
The Registrant confirms that unfunded commitments will not be counted toward the Fund’s compliance with Rule 35d-1.

 18. Comment: Where the Investment Opportunities and Strategies sub-section references “third-party
investment managers,” please use and/or reference the defined term Underlying Managers and disclose consistently throughout the
Registration Statement.

Response:
The Registrant has made the requested changes.

 19. Comment: Where the Investment Opportunities and Strategies sub-section references “(iii) investments
in the equity and/or debt of companies whose securities are not traded on any securities exchange, typically, but not always, alongside
Private Equity Funds (“Co-Investments”),” please describe with greater specificity what kind of private market assets
the Fund intends to invest in and will classify as private equity versus alternative investments. Additionally, the Fund should provide
more specificity concerning the debt and derivatives investments in which the Fund intends to invest, particularly in light of the Fund’s
name.

Response:
The Registrant has revised the disclosure to better clarify the types of Private Equity Investments and Alternative Investments that are
expected to be made by the Fund.

    6

 20. Comment: On page 7 the Investment Opportunities and Strategies sub-section, states
that “[t]he Fund expects to target Private Equity Investment opportunities primarily in North America and Europe, and in other
geographies on a limited basis” (emphasis added). Please revise the disclosure regarding other geographies with greater specificity.
Furthermore, the disclosure here refers generally to “other geographies”, whereas disclosure infra notes that the Fund's Private
Equity Investments may include “emerging markets” investments. If the Fund intends to invest principally in emerging markets,
please add corresponding disclosure to the Investment Opportunities and Strategies sub-section of the summary prospectus. Please also
consider presenting Emerging Markets Risk as a separate risk factor from Foreign Instruments.

Response:
The Registrant has updated the disclosure accordingly and added a separate Emerging Markets Risk factor.

 21. Comment: At the Fund Accounting and Administration Expenses sub-section, ple